Income Tax : Explore the rules and challenges of Domestic Transfer Pricing (DTP) in India. Learn about legal definitions, threshold limits, app...
Income Tax : Penalties for failing to maintain records of specified domestic transactions. Learn about arm's length pricing & essential documen...
Income Tax : Gain a comprehensive understanding of transfer pricing regulations with this informative article. Learn about Section 92A to 92F a...
Income Tax : The provisions of transfer pricing are designed to keep a check on the practice of reducing the tax liability by entering into tra...
Income Tax : The Finance Ministry vide Circular no. 17/2021 dated 09 September, 2021 announced extensions to the deadline for the filing of the...
Income Tax : From April 2025, TPOs can determine ALP for SDTs not initially referred or reported. This ensures accurate adjustments and complia...
Income Tax : The Income Tax Appellate Tribunal (ITAT) in Pune deleted the penalty in the Jyoti Paper Udyog Ltd Vs. ACIT case due to non-product...
Income Tax : ITAT Mumbai held that adjustment on account of examination of the arm’s-length price of the specified domestic transactions is n...
Income Tax : Finance Act, 2017 removed clause (i) of section 92BA, effectively nullifying any decisions made by the Assessing Officer under thi...
Income Tax : Held that a domestic transaction of purchase from the related party is not required to be considered as a specified domestic trans...
Income Tax : Garg Acrylics Ltd. Vs Addl. CIT (ITAT Delhi) It is the case of the assessee that reference made to the TPO in the instant case wit...
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 : Procedure for registration and submission of Statement of Reportable Account as per section 285BA of Income-tax Act, 1961 read wit...
Income Tax : Procedure for registration and submission of statement of financial transactions (SFT) as per section 285BA of Income-tax Act, 196...
Income Tax : As per sub-rule (1)(i) and sub-rule (4) of Rule 114D, the statement in Form No. 61 shall be furnished through online transmission ...
Income Tax : Under electronic verification, the individual or a person (not being a company or firm) who does not have a permanent account numb...
The provisions of transfer pricing are designed to keep a check on the practice of reducing the tax liability by entering into transactions at prices higher/lower than market prices with one or more associated entity.
ACIT Vs Electrosteel Casting Ltd. (ITAT Kolkata) It is clear from the rival contentions that determination price at which Power generated can be sold is subject to statutory control under the provisions of Section 61 & 62 of the Electricity Act, 2003. The Hon’ble Calcutta High Court in its decision rendered in the case of […]
The Finance Ministry vide Circular no. 17/2021 dated 09 September, 2021 announced extensions to the deadline for the filing of the Income-tax Returns, as well as some other allied compliances for the Assessment Year 2021-22: Sr. No. Particulars Original Due Date Extended to vide earlier Circular no.9/2021 Now Extended to vide Latest Circular no. 17/2021 […]
The related party transactions have always been under the close scanner of the Tax Authorities. Owing to the inherent nature of such transactions it is believed that such transactions are by far the most convenient way of shifting profits and accordingly subjected to detailed scrutiny by the Tax Authorities. The international transactions have been under […]
Commissioner issued a show cause notice under section 263 and ultimately passed impugned order; by that time the alleged domestic transaction of purchase from related party was not required to be considered as a specified domestic transaction under section 92BA of the Act. It has been omitted, and therefore, no proceedings under section 263 should have been undertaken by the ld. Commissioner.
Smt. Anita Sunil Mahajan Vs ACIT (ITAT Pune) Definition of ‘relative’ for Specified Domestic Transactions (SDTs) should be as per Section 2(41) of Income Tax Act, 1961 and Section 56(2)(v) would not apply. Case Summary: – Facts of the case: During AY 2013-14, Smt. Anita Sunil Mahajan (Assessee), filed her return declaring total income at […]
everting to the CUP method applied by assessee as the most appropriate method for benchmarking the SDT of rent payment, assessee had given a comparable instance of rent paid @ Rs.112 per sq.ft. by ICICI bank under a lease agreement dated 17.02.2012 for a nearby premises. As against that, the assessee paid rent @ Rs.75.28 per sq.ft., which showed that the rent paid by assessee was less in comparison with the comparable uncontrolled transaction. Thus, the ALP of the Specified Domestic Tranasction of payment of rent could not be disputed.
Sobha City Vs ACIT (ITAT Bangalore) No addition for transfer pricing (TP) adjustment related to Specified Domestic Transactions (SDT). Conclusion: The reference to TPO for transfer pricing adjustment in respect of specified domestic transactions mentioned in clause (i) of section 92BA was not valid, as the said provision had been omitted. Accordingly, AO was directed […]
DCIT Vs Convergys Customer Management Group Inc. (ITAT Delhi) It is mandatory for all taxpayers, without exception, to obtain an independent accountant’s report in respect of all international transactions between associated enterprises or specified domestic transactions. The report has to be furnished by the due date of the tax return filing. Even if it is […]
Merely because a prescribed Form No. 3CEB was filed in accordance with Rule 10E r.w.s. 92BA of the Act would not make an assessee susceptible to onerous investigation proceedings on such transactions where the assessee prima facie demonstrates that Section 92BA of the Act is wholly inapplicable in any manner at the first instance
