Income Tax : Section 144C of IT Act, 1961 was brought through Finance Act, 2009 & introduced for orderly assessment with respect to the interna...
Income Tax : Understand penalties for under-reporting and misreporting of income in transfer pricing adjustments, as per the Income Tax Act 196...
Income Tax : Chapter X of the Income Tax Act applies solely to transactions with Associated Enterprises (AEs), excluding non-AE transactions fr...
Income Tax : Revenue authorities lack jurisdiction to question the business decisions or commercial wisdom of taxpayers in transfer pricing cas...
Income Tax : The ITAT remands BorgWarner's case on TSS, BSS, and royalty benchmarking to TPO for re-determination, questioning the segregation ...
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 : What is the procedure to approve Form 3CEB? Form uploaded by CA shall be available under For your action tab in Taxpayer’s Workl...
Income Tax : ICAI Releases Exposure Draft Guidance Note On Report Under Section 92E Of Income-Tax Act, 1961 (Transfer Pricing) Based on the la...
Income Tax : Association for Corporate Advisers and Executives (ACAE) made a Request for Extension of Due Dates for filing Tax Audit and Transf...
Income Tax : Delhi High Court upheld the ITAT’s decision, concluding that the comparability analysis must focus on functional similarity rath...
Income Tax : Delhi High Court remands Alcatel Lucent's transfer pricing case to ITAT, questioning selection of comparables 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...
Income Tax : ITAT Delhi remands JCB India Ltd.'s ₹166.09 crore TP adjustment for non-UK royalty payments to TPO for fresh consideration....
Income Tax : Delhi HC ruling clarifies that KPO service providers aren't comparable to ITES providers for benchmarking international transactio...
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...
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 : 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...
Explore landmark cases like SAP Labs vs. IT Officer, Evalueserve vs. Commissioner, and Softbrands vs. IT. Learn how the law and facts intersect in transfer pricing disputes.
Discover how Artificial Intelligence is reshaping transfer pricing strategies for multinational enterprises, offering predictive insights, automation, and more.
In the case of ACIT vs. Avaya India Pvt. Ltd., ITAT Delhi excludes Infosys from the list of comparables under the software development services segment.
In PCIT vs. Hellmann Worldwide Logistics India Pvt. Ltd case, Delhi High Court upholds appellate authorities’ right to choose a different transfer pricing method.
ITAT Mumbai held that adjustment on account of examination of the arm’s-length price of the specified domestic transactions is not valid because of deletion of the provisions of Section 92BA (1) of the Act with effect from 1/4/2017. Provisions of Section 40A (2) of the act governs the allowability of those expenditure.
ITAT Mumbai held that Retail Sale Price Method (RPM) is the most appropriate method for benchmarking the international transaction of ‘import of men’s wear for resale’ between Celio Future Fashion Pvt. Ltd. and its associated enterprises.
ITAT Mumbai held that TP adjustment in respect of international transaction of reimbursement of Employee Stock Option Plan (ESOP) Expenses deleted as Arm’s Length Price (ALP) of ESOP expenses cannot be taken as NIL.
ITAT Mumbai held that there was no express arrangement / agreement between the assessee and the AE for incurring advertisement, marketing and promotional expenses (AMP) to promote the brand of the AE and hence the said transactions would not constitute international transaction relating to AMP expenditure. Thus, TP adjustment deleted.
ITAT Mumbai held that the determination of Arm’s Length Price (ALP) without applying any methods as prescribed under section 92C(1) of the Income Tax Act by the TPO is not tenable in law.
ITAT Mumbai held that the Indian Subsidiary operating in an independent manner doesn’t constitute as a “Permanent Establishment” in India and hence income of the assessee is not allowable to be taxed in India.
