Income Tax : The Income Tax Act 2025 introduces mandatory reporting of high-value gifted immovable properties exceeding ₹45 lakh. The amendme...
Income Tax : Clause 43 in Tax Audit Form No. 26 requires auditors to verify remittances reported in Part-D of Form 145. Incorrect classificatio...
Income Tax : The new Income Tax Act, 2025 significantly reduces the number of statutory sections and reorganises tax compliance procedures effe...
Income Tax : The new law defines strict conditions for reopening assessments using specified information categories. It ensures transparency an...
Income Tax : The reform consolidates TDS provisions into a structured system and introduces digital compliance mechanisms. It enhances clarity,...
Income Tax : Rules 307–311 of the Draft Income-tax Rules, 2026 outline how pension funds must purchase annuities, restrict commutation, preve...
Income Tax : Draft Income-tax Rules 2026 prescribe definitions, trust conditions, investment rules, and limits on employer contributions for ap...
Income Tax : Draft Income-tax Rules 2026 outline procedures for provident fund recognition, penalties for assigning PF interest, and tax treatm...
Income Tax : Draft Income-tax Rules 2026 require provident fund nominations to favour family members and mandate annual account reporting by tr...
Income Tax : Rule 333 mandates electronic tax payments for companies and specified taxpayers, while the draft rules also prescribe detailed dep...
Income Tax : Rule 81 prescribes dataset construction, weighted averages, and a 35th–65th percentile arm’s length range when multiple compar...
Income Tax : The latest amendment excludes income arising from transfer of pre-2017 investments from GAAR scrutiny. It reinforces the protectio...
Income Tax : CBDT introduced Income-tax Rules, 2026 to operationalize the Income-tax Act, 2025. The rules standardize procedures on valuation, ...
Draft Rule 88 of the Income-tax Rules, 2026 clearly identifies the categories of international transactions that qualify for safe harbour, helping taxpayers determine eligibility and reduce transfer pricing disputes.
Draft Rule 87 of the Income-tax Rules, 2026 specifies categories of eligible assessees and lays down stringent low-risk conditions to ensure certainty and simplified compliance under safe harbour transfer pricing rules.
Rules 85 and 86 of the Draft Income-tax Rules, 2026 mandate accountant certification for international and specified domestic transactions and define key terms for safe harbour rules. The provisions aim to standardize reporting timelines and clarify eligibility criteria for transfer pricing compliance.
Draft Rule 84 of the Income-tax Rules, 2026 requires taxpayers entering international or specified domestic transactions to maintain extensive contemporaneous documentation to substantiate arm’s length pricing and avoid disputes.
Draft Rule 83 of the Income-tax Rules, 2026 mandates a 90-day repatriation deadline for excess money arising from secondary transfer pricing adjustments, failing which imputed interest is levied at prescribed benchmark rates.
Rule 82 allows assessees to determine arm’s length price for two additional consecutive years in a single transfer pricing proceeding, provided strict similarity and compliance conditions are satisfied. The key takeaway: the option is available only where transactions, methods, and functional profiles remain materially unchanged.
Rule 81 prescribes dataset construction, weighted averages, and a 35th–65th percentile arm’s length range when multiple comparable prices arise, with the median applied if the transaction falls outside the range.
Draft Rule 80 prescribes criteria for selecting the most appropriate transfer pricing method based on transaction nature, comparability, data reliability, and functional analysis.
Draft Rule 79 sets out recognized methods and comparability criteria for determining arm’s length price under section 165, mandating use of the most appropriate method and current-year data for accurate benchmarking.
Draft Rules 77 and 78 clarify essential transfer pricing definitions and allow an alternative comparability-based method for determining arms length price. The provisions expand scope while enabling practical pricing based on similar uncontrolled transactions.
