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Transfer Pricing

Latest Articles


Key ITAT Rulings: Reassessment, Section 80G, DTAA & Transfer Pricing

Income Tax : Explore recent ITAT judgments on reassessment validity, 80G exemptions, DTAA interpretation for online education (FTS/Royalty), tr...

June 7, 2025 645 Views 0 comment Print

Significant Economic Presence (SEP): Exclusion for Export-Oriented Purchases

Income Tax : India's Finance Act 2025 clarifies Significant Economic Presence (SEP) rules, excluding mere purchase of goods in India for export...

May 19, 2025 315 Views 0 comment Print

Future of International Taxation: OECD Global Minimum Tax

Income Tax : Learn about income tax exemptions for universities, hospitals, and educational institutions under Section 10 of the Income Tax Act...

March 11, 2025 618 Views 0 comment Print

Budget 2025: Transfer Pricing Amendments

Income Tax : Learn about the amendments to Section 92CA concerning references to the Transfer Pricing Officer for determining arm's length pric...

February 4, 2025 1677 Views 0 comment Print

Transfer Pricing Amendments: Multi-Year ALP Determination

Income Tax : New transfer pricing rules allow arm’s length price (ALP) determinations to apply for two consecutive years, reducing compliance...

February 3, 2025 1089 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 1170 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 579 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 13800 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Draft Guidance Note on Transfer Pricing Report – Section 92E

Income Tax : ICAI Releases Exposure Draft Guidance Note On Report Under Section 92E Of Income-Tax Act, 1961 (Transfer Pricing) Based on the la...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 26208 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 11859 Views 1 comment Print


Latest Judiciary


Bombay HC Dismisses Revenue Appeal on Transfer Pricing

Income Tax : The Bombay High Court dismissed Revenue's appeal against Everest Kanto Cylinder Ltd., citing prior judgments on identical transfer...

June 15, 2025 72 Views 0 comment Print

Calcutta HC Upholds 0.5% Corporate Guarantee Fee Rate in transfer pricing case

Income Tax : Calcutta High Court dismisses Revenue appeal, affirming ITAT's deletion of transfer pricing adjustment on corporate guarantee comm...

June 12, 2025 174 Views 0 comment Print

HC upholds Interest Rate on Corporate Guarantee to 0.5% Under Section 92C

Income Tax : Bombay High Court dismissed PCIT's appeal against Manugraph India Ltd., affirming lower interest rates on AE loans and corporate g...

June 12, 2025 207 Views 0 comment Print

Pune ITAT Remands TP Issue on Spare Parts Exports, Allows Partial Relief on Corporate Guarantee Fee

Income Tax : ITAT Pune remands Piaggio Vehicles' transfer pricing dispute on export segmentation, citing need for verification, while upholding...

June 9, 2025 150 Views 0 comment Print

Transfer Pricing: ITAT Delhi Favors Segmental ALP, Rejects Notional Interest

Income Tax : ITAT Delhi directs segment-wise ALP, includes Fiberfox comparable, and rejects notional interest on AE dues for Opterna Technologi...

May 18, 2025 210 Views 0 comment Print


Latest Notifications


Amendment of Safe Harbour Rules for AY 2025-26 under Section 92CB

Income Tax : CBDT notifies Income Tax (Sixth Amendment) Rules, 2025, introducing safe harbour rules for assessment year 2025-26. Full details o...

March 25, 2025 1584 Views 0 comment Print

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 1695 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 3807 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 12117 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 1797 Views 0 comment Print


Latest Posts in Transfer Pricing

Bombay HC Dismisses Revenue Appeal on Transfer Pricing

June 15, 2025 72 Views 0 comment Print

The Bombay High Court dismissed Revenue’s appeal against Everest Kanto Cylinder Ltd., citing prior judgments on identical transfer pricing issues.

Calcutta HC Upholds 0.5% Corporate Guarantee Fee Rate in transfer pricing case

June 12, 2025 174 Views 0 comment Print

Calcutta High Court dismisses Revenue appeal, affirming ITAT’s deletion of transfer pricing adjustment on corporate guarantee commission at 0.5%.

HC upholds Interest Rate on Corporate Guarantee to 0.5% Under Section 92C

June 12, 2025 207 Views 0 comment Print

Bombay High Court dismissed PCIT’s appeal against Manugraph India Ltd., affirming lower interest rates on AE loans and corporate guarantees based on established precedent from Everest Kanto Cyliners Ltd.

Pune ITAT Remands TP Issue on Spare Parts Exports, Allows Partial Relief on Corporate Guarantee Fee

June 9, 2025 150 Views 0 comment Print

ITAT Pune remands Piaggio Vehicles’ transfer pricing dispute on export segmentation, citing need for verification, while upholding corporate guarantee fee allowance based on judicial precedents.

Key ITAT Rulings: Reassessment, Section 80G, DTAA & Transfer Pricing

June 7, 2025 645 Views 0 comment Print

Explore recent ITAT judgments on reassessment validity, 80G exemptions, DTAA interpretation for online education (FTS/Royalty), transfer pricing methodologies, and cash deposit explanations under Section 68.

Significant Economic Presence (SEP): Exclusion for Export-Oriented Purchases

May 19, 2025 315 Views 0 comment Print

India’s Finance Act 2025 clarifies Significant Economic Presence (SEP) rules, excluding mere purchase of goods in India for export from tax liability.

Transfer Pricing: ITAT Delhi Favors Segmental ALP, Rejects Notional Interest

May 18, 2025 210 Views 0 comment Print

ITAT Delhi directs segment-wise ALP, includes Fiberfox comparable, and rejects notional interest on AE dues for Opterna Technologies, remits Section 68 issue.

TPO to determine ALP of royalty payment using TNMM method: ITAT Bangalore

May 17, 2025 258 Views 0 comment Print

ITAT Bangalore held that disallowance of entire royalty payment by taking ALP at NIL not justified since there is no change in facts, circumstances or functions and hence principle of consistency should be applied.

AMP Expenses Not Separate International Transactions Without Evidence of Inter-Enterprise Transaction

May 14, 2025 168 Views 0 comment Print

Delhi High Court dismisses tax appeal against Wrigley India, affirming AMP expenses not separate international transaction without evidence, citing precedents.

TNMM Doesn’t Mandate Audited Segmental Accounts for Internal Comparables

May 14, 2025 510 Views 0 comment Print

ITAT Delhi deletes transfer pricing adjustment on engineering services for Lummus Technology Heat Transfer BV, citing Delhi High Court rulings.

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