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 ...
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 […]
Mobileum Inc Vs DCIT (ITAT Mumbai) since transactions between the assessee and its AE have been found at arm’s length prices no further income chargeable to tax in India can be said to be attributable for the PE of the assessee. FULL TEXT OF THE ORDER OF ITAT MUMBAI This appeal by the Assessee is […]
Two-pillar solution for Tax challenges arising from Digitalisation of Economy and consensus of majority of OECD/ G20 member countries (including India) Executive summary Certainty is one of the basic cannons of taxation. With the globalisation of economy when Multi National Enterprises (MNEs) starting setting up businesses across the globe, levy of tax in multiple countries […]
A transaction in which the buyers and sellers of a product act independently and have no relationship to each other. The concept of an arm’s length transaction is to ensure that both parties in the deal are acting in their own self interest and are not subject to any pressure or duress from the other party
The issue under consideration is whether the TPO is correct in considering subvention fee in the BPO segment instead of distribution segment?
If a company is having huge asset base, brand value, goodwill and presence in global market with significant R & D, then it cannot be compared with a company which is purely captive service provider in ITeS/BPO, having low risk and insignificant assets.
