Income Tax : Form 46 allows taxpayers to exercise the option for determination of arm’s length price for international or specified domestic ...
Income Tax : The ruling explains strict compliance requirements for specified domestic transactions, including maintaining detailed documentati...
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...
Finance : The Finance Bill 2025 proposes multi-year ALP determination to reduce compliance burdens in transfer pricing. Learn about its fram...
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 : Supreme Court dismissed the SLP, affirming that ITAT rightly remanded the case to TPO to reassess ALP of intra-group services, str...
Income Tax : The Mumbai ITAT upheld TNMM for Firmenich Aromatics, deleting transfer pricing adjustments on exports and royalties, and allowed a...
Income Tax : Kolkata ITAT rules corporate guarantee is international transaction but limits transfer pricing adjustment to 0.5% for Tega Indust...
Income Tax : ITAT Ahmedabad clarifies corporate guarantees as international transactions, yet upholds Adani Ports' appeal on no arm's length a...
Income Tax : ITAT Delhi directs segment-wise ALP, includes Fiberfox comparable, and rejects notional interest on AE dues for Opterna Technologi...
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 ...
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.
In India, the underlying idea behind the scheme of APA is to make tax administration better and efficient by encouraging taxpayers to provide all the data essential for a comprehensive transfer pricing analysis and to motivate them towards engaging a mutual agreement.
Lambda Therapeutic Research Ltd. Vs DCIT (ITAT Ahmedabad) We find that the assessee has not demonstrated any benefit derived from its associated enterprises namely Lambda USA whereas it has advanced interest free loan of EURO 49,999/-. Thus, the question arises whether there is a need to make any adjustment on account of notional interest under […]
ALP of corporate guarantee has to be determined as it falls within scope and ambit of an international transaction after retrospective amendment to section 92B and 0.5% corporate guarantee is held to be appropriate.
The TPO and DRP erred in treating CCDs as ECBs and benchmarked the interest rate against LIBOR rate. The CCDs is a hybrid instrument and cannot be per se treated as ECB / loan.
Implementation plan for the two-pillar solution to address tax challenges of a digital economy Background In my earlier article dated July 19, 2021, I have given a brief overview of the Statement on a two‑pillar solution to address the tax challenges arising from the digitalisation of the economy (the Statement) that was agreed by 130 […]
