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Transfer Pricing

Latest Articles


Transfer Pricing Adjustments: Under-Reporting & Misreporting

Income Tax : Understand penalties for under-reporting and misreporting of income in transfer pricing adjustments, as per the Income Tax Act 196...

November 24, 2024 3468 Views 0 comment Print

Chapter X of Income tax Act not applicable to non-AE transactions

Income Tax : Chapter X of the Income Tax Act applies solely to transactions with Associated Enterprises (AEs), excluding non-AE transactions fr...

November 4, 2024 1179 Views 0 comment Print

Revenue authorities lack jurisdiction to question commercial wisdom of taxpayer

Income Tax : Revenue authorities lack jurisdiction to question the business decisions or commercial wisdom of taxpayers in transfer pricing cas...

October 19, 2024 726 Views 0 comment Print

Aggregation vs. Segregation Approach in Benchmarking International Transactions

Income Tax : The ITAT remands BorgWarner's case on TSS, BSS, and royalty benchmarking to TPO for re-determination, questioning the segregation ...

September 25, 2024 396 Views 0 comment Print

Recharacterization of Transaction in Transfer Pricing

Income Tax : Explore the concept of transaction recharacterization in transfer pricing. Understand its rationale, benefits, and challenges in g...

August 13, 2024 420 Views 0 comment Print


Latest News


Tolerance Range for Transfer Pricing Notified for AY 2024-25

Income Tax : CBDT sets transfer pricing tolerance range at 1% for wholesale trading and 3% for other transactions for AY 2024-25, providing cla...

October 30, 2024 645 Views 0 comment Print

Budget 2024: TPO can evaluate SDTs not reported by taxpayers

Income Tax : From April 2025, TPOs can determine ALP for SDTs not initially referred or reported. This ensures accurate adjustments and complia...

July 26, 2024 369 Views 0 comment Print

FAQ’s on filing of Income Tax Form 3CEB

Income Tax : What is the procedure to approve Form 3CEB? Form uploaded by CA shall be available under For your action tab in Taxpayer’s Workl...

October 28, 2022 13434 Views 0 comment Print

Draft Guidance Note on Transfer Pricing Report – Section 92E

Income Tax : ICAI Releases Exposure Draft Guidance Note On Report Under Section 92E Of Income-Tax Act, 1961 (Transfer Pricing) Based on the la...

July 21, 2022 26085 Views 1 comment Print

ACAE Requested due date extension for filing Tax & TP Audit

Income Tax : Association for Corporate Advisers and Executives (ACAE) made a Request for Extension of Due Dates for filing Tax Audit and Transf...

January 7, 2022 11739 Views 1 comment Print


Latest Judiciary


Comparability Analysis must Focus on Functional Similarity Over Product Matching: Delhi HC

Income Tax : Delhi High Court upheld the ITAT’s decision, concluding that the comparability analysis must focus on functional similarity rath...

December 5, 2024 147 Views 0 comment Print

Comparable Selection for Arm’s Length Price Relies on Functional Similarity

Income Tax : Delhi High Court remands Alcatel Lucent's transfer pricing case to ITAT, questioning selection of comparables in ALP determination...

November 3, 2024 366 Views 0 comment Print

High Brand Value, Large-Scale Operations & Lack of Segmented Data are valid Ground for Exclusion in ALP Determination

Income Tax : Delhi High Court judgment on Cadence Design's appeal against the ITAT order regarding transfer pricing comparables. Key findings o...

November 1, 2024 147 Views 0 comment Print

TP Adjustment of ₹166.09 Crore for Non-UK Royalties payment Remanded back to TPO

Income Tax : ITAT Delhi remands JCB India Ltd.'s ₹166.09 crore TP adjustment for non-UK royalty payments to TPO for fresh consideration....

October 31, 2024 54 Views 0 comment Print

KPO Service Provider Not Comparable to ITES for Transfer Pricing Benchmarking

Income Tax : Delhi HC ruling clarifies that KPO service providers aren't comparable to ITES providers for benchmarking international transactio...

October 14, 2024 291 Views 0 comment Print


Latest Notifications


Tolerance Range for Arm’s Length Price in FY 2024-25

Income Tax : CBDT sets 1% tolerance for wholesale trading and 3% for other cases under Section 92C for FY 2024-25. No adverse effects from retr...

October 18, 2024 873 Views 0 comment Print

Income-tax (Twenty-Ninth Amendment) Rules, 2023

Income Tax : Stay informed on the latest Income Tax Rule changes with Notification No. 104/2023 by the Ministry of Finance. Learn about amendme...

December 19, 2023 3543 Views 0 comment Print

CBDT extends applicability of Safe Harbour rules to AY 2023-24

Income Tax : Read how CBDT's Notification No. 58/2023 amends Income-tax Rules, extending Safe Harbour rules to AY 2023-24. Insights from Minist...

August 9, 2023 11718 Views 0 comment Print

Deemed Arm’s Length Price for Assessment Year 2023-2024

Income Tax : Notification No. 46/2023-Income-Tax Dated: 26th June, 2023  regarding deemed arm's length price for assessment year 2023-2024. Le...

June 26, 2023 1677 Views 0 comment Print

Tolerance Band for AY 2022-23 in case of wholesale trading & others

Income Tax : In exercise of the powers conferred by the third proviso to sub-section (2) of section 92C of the Income-tax Act, 1961 (43 of 1961...

June 28, 2022 2517 Views 0 comment Print


Latest Posts in Transfer Pricing

Comparability Analysis must Focus on Functional Similarity Over Product Matching: Delhi HC

December 5, 2024 147 Views 0 comment Print

Delhi High Court upheld the ITAT’s decision, concluding that the comparability analysis must focus on functional similarity rather than strict product comparability, and that certain disallowances made by the Assessing Officer were unjustified.

Transfer Pricing Adjustments: Under-Reporting & Misreporting

November 24, 2024 3468 Views 0 comment Print

Understand penalties for under-reporting and misreporting of income in transfer pricing adjustments, as per the Income Tax Act 1961.

Chapter X of Income tax Act not applicable to non-AE transactions

November 4, 2024 1179 Views 0 comment Print

Chapter X of the Income Tax Act applies solely to transactions with Associated Enterprises (AEs), excluding non-AE transactions from transfer pricing provisions.

Comparable Selection for Arm’s Length Price Relies on Functional Similarity

November 3, 2024 366 Views 0 comment Print

Delhi High Court remands Alcatel Lucent’s transfer pricing case to ITAT, questioning selection of comparables in ALP determination. Detailed review of objections awaited.

High Brand Value, Large-Scale Operations & Lack of Segmented Data are valid Ground for Exclusion in ALP Determination

November 1, 2024 147 Views 0 comment Print

Delhi High Court judgment on Cadence Design’s appeal against the ITAT order regarding transfer pricing comparables. Key findings on ALP determination and comparability.

TP Adjustment of ₹166.09 Crore for Non-UK Royalties payment Remanded back to TPO

October 31, 2024 54 Views 0 comment Print

ITAT Delhi remands JCB India Ltd.’s ₹166.09 crore TP adjustment for non-UK royalty payments to TPO for fresh consideration.

Tolerance Range for Transfer Pricing Notified for AY 2024-25

October 30, 2024 645 Views 0 comment Print

CBDT sets transfer pricing tolerance range at 1% for wholesale trading and 3% for other transactions for AY 2024-25, providing clarity to taxpayers.

Revenue authorities lack jurisdiction to question commercial wisdom of taxpayer

October 19, 2024 726 Views 0 comment Print

Revenue authorities lack jurisdiction to question the business decisions or commercial wisdom of taxpayers in transfer pricing cases, ITAT rulings emphasize.

Tolerance Range for Arm’s Length Price in FY 2024-25

October 18, 2024 873 Views 0 comment Print

CBDT sets 1% tolerance for wholesale trading and 3% for other cases under Section 92C for FY 2024-25. No adverse effects from retrospective application.

KPO Service Provider Not Comparable to ITES for Transfer Pricing Benchmarking

October 14, 2024 291 Views 0 comment Print

Delhi HC ruling clarifies that KPO service providers aren’t comparable to ITES providers for benchmarking international transactions.

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