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Transfer Pricing

Latest Articles


Assurance at Stake: Difficulties of PPT in light of BEPS Action 6 and MLI

Income Tax : Explore the Principal Purpose Test (PPT) in international tax law, its impact on treaty benefits, legal uncertainty, and potential...

March 26, 2025 174 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 549 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 1395 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 975 Views 0 comment Print

Transfer Pricing: Multi-Year ALP Determination in Budget 2025 – FAQs

Income Tax : Finance Bill 2025 allows multi-year Arm’s Length Price determination for similar transactions, reducing repetitive proceedings i...

February 2, 2025 654 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 1095 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 534 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 13704 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Draft Guidance Note on Transfer Pricing Report – Section 92E

Income Tax : ICAI Releases Exposure Draft Guidance Note On Report Under Section 92E Of Income-Tax Act, 1961 (Transfer Pricing) Based on the la...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 26172 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 11835 Views 1 comment Print


Latest Judiciary


Resale Price Method most appropriate as assessee acts as distributor and makes no value addition

Income Tax : Delhi High Court held that Resale Price Method (RPM) is the most appropriate method to determine arm’s length price since assess...

April 2, 2025 168 Views 0 comment Print

Existence of International Transaction Must Be Analyzed Before Benchmarking AMP Expense

Income Tax : Delhi High Court held that before undertaking a benchmarking of Advertisement, Marketing and Promotion [AMP expenses], it was incu...

March 31, 2025 81 Views 0 comment Print

Cost Allocation and Transfer Pricing – ITAT Bangalore Ruling

Income Tax : Advocate Amardeep Soni & Advocate Harsha Soni Gemplus India Pvt. Ltd. Vs ACIT (ITAT Bangalore) A Case Study of ITAT BANGALORE...

March 19, 2025 372 Views 0 comment Print

Fresh Adjudication Ordered on TPO Adjustment in Subsidiary Transaction

Income Tax : Bangalore ITAT overturns AO's PE classification of QlikTech India, orders fresh review based on TPO order, addresses TDS and inter...

March 9, 2025 93 Views 0 comment Print

Indian Subsidiary Not a Dependent Agency PE if Transactions Are Subject to TPO Adjustment

Income Tax : ITAT Bangalore sets aside AO's decision in Qlik Tech International AB vs DCIT, addressing PE classification, TDS credit, and tax r...

March 8, 2025 198 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 972 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 1485 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 3750 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 12021 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 1758 Views 0 comment Print


Thin Cap Adjustment Provisions Under Section 94B

January 20, 2024 8988 Views 2 comments Print

Explore the Thin Cap Adjustment Provisions under Section 94B of the Income Tax Act, addressing base erosion and profit shifting. Learn about its impact on NBFCs, start-ups, and global approaches.

Delhi High Court Upholds 15% Attribution Rate for Travelport

January 19, 2024 555 Views 0 comment Print

Delhi HC upholds 15% attribution rate of revenue for Indian operations of Permanent Establishment based on gross booking by Travelport Global Distribution Systems B.V.

Delhi HC Upholds ITAT Order Excluding Comparables Due to Functional Dissimilarity

January 19, 2024 501 Views 0 comment Print

Delhi High Court upholds ITAT’s decision to exclude comparables Accentia, Eclerx, Mold-Tek, and TSR in the PCIT vs. Honeywell International transfer pricing case.

Summary of Hon’ble ITAT Pune decision on Transfer Pricing in the year 2023

January 9, 2024 1695 Views 0 comment Print

Explore detailed analysis of Hon’ble ITAT Pune decisions in 2023 on transfer pricing, covering allocation of expenses, custom duty, working capital, methods, and more.

Transfer pricing audit under section 92E of the income tax act, 1961

January 5, 2024 4890 Views 0 comment Print

Understand the intricacies of Transfer Pricing Audits in international transactions, mandated by Section 92E of the Income Tax Act, 1961. Learn how to ensure compliance, maintain accurate documentation, and avoid disputes, safeguarding your company’s global tax practices.

Inadequate information & distinct functional profile: Comparable cannot be accepted

January 4, 2024 789 Views 0 comment Print

Delhi High Court upholds ITAT order in PCIT Vs WSP Consultants India Pvt Ltd for AY 2012-13. Analysis of PLI computation and rejection of comparable Korus Engineering Solutions.

Decoding Grant Thornton Case: Impact on Cross-Border Transactions

January 4, 2024 1221 Views 0 comment Print

Explore Grant Thornton India LLP case, unraveling complex international tax issues. Analysis of arguments, rulings, and broader implications for businesses in cross-border transactions.

Related Party Transactions: AS 18 vs. Transfer Pricing in India

January 3, 2024 4176 Views 0 comment Print

Explore intricacies of Related Party Transactions under AS 18 and Transfer Pricing in India. Understand control, influence, disclosure requirements and how arm’s length principle is applied.

CIT vs Travelport: Delhi HC Upholds 15% Revenue Attribution to PE in India

December 22, 2023 552 Views 0 comment Print

Delhi High Court grants relief to Travelport LP USA as it upholds CIT’s 15% revenue attribution to PE in India. Full text and analysis of the judgment.

Bank guarantees are different from corporate guarantees; HC accepts 0.5% Guarantee Commission Rate

December 22, 2023 1272 Views 0 comment Print

Bombay HC clarifies bank guarantee vs. corporate guarantee distinctions in Everest Kento Cylinders case. Ruling impacts income tax computation.

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