Income Tax : Learn how Section 161 of the Income-tax Act, 2025 establishes the arm's length principle for international and specified domestic ...
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 : This article explains how Safe Harbour Rules under the Income-tax Act, 2025 interact with APAs, MAP provisions, and transfer prici...
Income Tax : The framework outlines mandatory disclosures and timelines for opting into safe harbour. Key takeaway: strict compliance is essent...
Income Tax : CBDT signed a record number of APAs to provide clarity on transfer pricing and reduce disputes. The framework ensures advance dete...
CA, CS, CMA : KSCAA urged CBDT to extend due dates for assessees under Section 92E, citing an omission in Circular No. 15/2025 that created inco...
CA, CS, CMA : Chartered Accountants Association, Ahmedabad requests extension of ITR and audit due dates for AY 2025-26 citing compressed timeli...
Income Tax : CBDT sets transfer pricing tolerance range at 1% for wholesale trading and 3% for other transactions for AY 2024-25, providing cla...
Income Tax : From April 2025, TPOs can determine ALP for SDTs not initially referred or reported. This ensures accurate adjustments and complia...
Income Tax : ITAT Delhi held that documentary evidence established receipt of intra-group administrative support services and that the 5% marku...
Income Tax : ITAT held forex loss from ECB and capital transactions is non-operating for TP purposes and directed recomputation of PLI....
Income Tax : ITAT held that increased employee remuneration cannot be disallowed merely because business revenue declined where the expenditure...
Income Tax : The ITAT Pune held that detailed agreements, invoices and supporting records established that management support services were act...
Income Tax : ITAT excluded EDCIL, Just Dial, Info Edge and India Exposition Mart as transfer pricing comparables due to functional differences ...
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 : CBDT notifies Income Tax (Sixth Amendment) Rules, 2025, introducing safe harbour rules for assessment year 2025-26. Full details o...
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...
Income Tax : Stay informed on the latest Income Tax Rule changes with Notification No. 104/2023 by the Ministry of Finance. Learn about amendme...
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...
ITAT Delhi held that documentary evidence established receipt of intra-group administrative support services and that the 5% markup was at arm’s length. The transfer pricing adjustment was accordingly deleted.
ITAT held forex loss from ECB and capital transactions is non-operating for TP purposes and directed recomputation of PLI.
ITAT held that increased employee remuneration cannot be disallowed merely because business revenue declined where the expenditure is justified and supported.
The ITAT Pune held that detailed agreements, invoices and supporting records established that management support services were actually rendered by the Associated Enterprise. It ruled that the payment was at arm’s length and deleted the entire transfer pricing adjustment.
ITAT excluded EDCIL, Just Dial, Info Edge and India Exposition Mart as transfer pricing comparables due to functional differences and restored one comparable for verification.
The ITAT Ahmedabad held that royalty payments should continue to be benchmarked under TNMM by following earlier decisions in the assessees own case. It found no reason to replace TNMM with CUP where identical facts had already been decided. The Department’s transfer pricing challenge was therefore dismissed.
ITAT upheld taxation of IPS and CEV subsidies following the Section 2(24) amendment, while partly allowing the appeal on other issues.
The ITAT Mumbai held that the rejection of the assessees certified segmental results was unsupported by cogent material and based on surmises. It directed the TPO to consider the audited segmental accounts while benchmarking the international transaction.
The Karnataka High Court held that where the Revenue had consistently accepted the same interest rate in earlier and subsequent assessment years, it could not adopt a different approach for a single year without justification. The appeal challenging the ITAT’s order was dismissed.
ITAT deleted the TP adjustment, allowed 60% software depreciation, but upheld other disallowances, partly allowing the appeal.
