Income Tax : Taxpayers entering specified domestic transactions exceeding prescribed thresholds must maintain transfer pricing documentation, a...
Income Tax : The article explains how multinational digital companies generate substantial revenue from Indian users while shifting profits to ...
Income Tax : Form 46 allows taxpayers to exercise the option for determination of arm’s length price for international or specified domestic ...
Finance : A summary of the UAE Corporate Tax Law's definitions for related parties under Article 35 and the arm's length principle in Articl...
Income Tax : Finance Bill 2025 allows multi-year Arm’s Length Price determination for similar transactions, reducing repetitive proceedings i...
Income Tax : Notification of Transfer Pricing Rules to incorporate range concept and use of multi-year data to reduce litigation on transfer pr...
Income Tax : ITAT Delhi remanded ALP adjustment issues for fresh FAR analysis of two comparables and reconsideration of working capital adjustm...
Income Tax : The ITAT held that where transactions with the Indian associated enterprise are at arm's length, additional profit attribution to ...
Income Tax : The ITAT found inconsistencies in the selection and rejection of comparable companies for determining the arm’s length price of ...
Income Tax : The Chennai ITAT held that transfer pricing benchmarking cannot ignore extraordinary business circumstances arising from the shutd...
Income Tax : Supreme Court dismissed the SLP, affirming that ITAT rightly remanded the case to TPO to reassess ALP of intra-group services, str...
Income Tax : Notification 157/2025 sets 1% tolerance for wholesale trading and 3% for all other cases for Arm's Length Price variation for AY 2...
Income Tax : Notification No. 46/2023-Income-Tax Dated: 26th June, 2023 regarding deemed arm's length price for assessment year 2023-2024. Le...
Income Tax : Central Government hereby notifies that where the variation between the arm’s length price determined under section 92C and the ...
Read the full text of the Delhi High Court judgment in the CIT vs. Sumitomo Corporation India Pvt Ltd case, concerning Assessment Years 2012-13 and 2013-14. TNMM found suitable for determining ALP for international indenting-transactions.
ITAT Mumbai held that the TPO is not correct in arriving at the ALP as NIL on the ground that the need and benefit test is not satisfied by the assessee without giving any contrary findings with regard to the various documents including the TP study submitted by the assessee.
Notification No. 46/2023-Income-Tax Dated: 26th June, 2023 regarding deemed arm’s length price for assessment year 2023-2024. Learn about the tolerance range for wholesale trading and other cases in international transactions or specified domestic transactions.
ITAT Bangalore held that if the net profit margin meets the Arm’s length price, then no separate addition needs to be made. Accordingly, TPO directed to delete the adjustment made towards Advertising Marketing Price (AMP) expenses.
Tribunal Decision determining ALP can be challenged on grounds of perversity & non observance of transfer pricing rules in individual cases
Toyota Kirloskar Motor (P) Ltd Vs ACIT (ITAT Bangalore) The Appellant submits the in its own case for AY 2003-04, the Honourable Bangalore Tribunal has accepted that TP adjustment has to restricted to AE transactions. Further, in Appellants own case for AY 2013-14 [ITA No.2016/Bang/2018, dated 18.08.2021], the Honourable Bangalore Tribunal has upheld the action […]
Arm’s Length Price of a transaction can be referred to as such price at which the business profits can be maximized commensurating with the functions performed, assets utilized and risk assumed in such transaction including the fundamental criterion of allocating business income/profits in different tax jurisdictions.
Court is of the view that every Assessment Year is a separate unit which is governed by its own peculiar facts and difference of opinion between the parties, as to the appropriateness of one or the other methods to calculate arm’s length price, cannot per se be a ground for interference
The arm’s length range is an everchanging range as different transfer pricing methods yield a different range of figures which may all be workable. With regard to this, the arm’s length principle can only generate a comparison of the set of conditions that would have been approved between independent enterprises.
While it may not be perfect, the member countries of the OECD focus have a tendency that the arm’s length principle should govern the judgment of transfer pricing between associated enterprises.
