Income Tax : The article explains how transactions between associated domestic entities exceeding ₹20 crore must comply with arm's length pri...
Income Tax : Taxpayers entering specified domestic transactions exceeding prescribed thresholds must maintain transfer pricing documentation, a...
Income Tax : The article explains how safe harbour rules simplify transfer pricing compliance. It highlights that eligible transactions are acc...
Income Tax : The new Form 48 replaces Form 3CEB and mandates reporting of international and domestic transactions. It enhances structured trans...
Income Tax : Explore the rules and challenges of Domestic Transfer Pricing (DTP) in India. Learn about legal definitions, threshold limits, app...
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...
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
Applicability of transfer pricing provisions was earlier limited to International Transactions only. With effect from 01.04.2013, the scope of Transfer Pricing provisions is extended to ‘Specified Domestic Transactions’ and is accordingly applicable from A.Y. 2013-14.
Since clause (i) section 92A was omitted with effect from 1st April, 2017 and the effect of such omission is that the said clause(i) was never existed in the statute. Hence, Ld. PCIT can not exercise the jurisdiction u/s 263 of the Act.
AS 18 defines the disclosure requirements related to related party relationship and transaction between a reporting enterprise and its related parties in the financial statement of that enterprise. The basic assessment during disclosure is centered upon two things viz., who is related party and what amounts to related party transaction. As per AS 18, following is the definition of related party.
Hon’ble Bombay High Court (HC) held that the transfer pricing officer (TPO) cannot suo-motu assume jurisdiction to determine the arm’s length price (ALP) of specified domestic transactions (SDT) not referred to him.
Transaction of purchase of loan from HDFC ltd. would not cover within the meaning of Specified Domestic Transactions (SDTs) as the shareholding of HDFC Ltd. of 16.39% could not be clubbed with the shareholding of the HDFC Investments Ltd. of 6.25% to cross the threshold limit of substantial interest of 20%.
SDT includes payments to related parties, inter-unit transfer of goods or services of profit linked tax holiday-eligible units, transactions of profit-linked tax holiday-eligible units with other parties and any other transaction that may be notified by the Central Board of Direct Taxes.
Transfer pricing provisions were earlier restricted to international transactions. With effect from 1.4.2013 , the scope of transfer pricing provisions gets extended to specified domestic transactions (SDT) exceeding Rupees twenty crore.
Procedure for registration and submission of Statement of Reportable Account as per section 285BA of Income-tax Act, 1961 read with Rule 114G of Income-tax Rules, 1962.
