Income Tax : The update outlines revised compliance forms, timelines, and penalties under the new rules. It highlights a structured transition ...
Corporate Law : The issue was identifying the correct transfer pricing method for intercompany transactions. The conclusion holds that TNMM is app...
Income Tax : The Tribunal held that the Indian entity was only a distributor and not a technology or content owner. It rejected the Revenue’s...
Income Tax : This explains the new block assessment mechanism allowing ALP to apply across multiple years. It emphasizes reduced disputes and s...
Income Tax : The issue concerns replacement of Form 3CEB with a new reporting framework. The reform mandates structured reporting with enhanced...
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 : The issue was whether high-turnover companies can be compared with a smaller software service provider. The Tribunal held that com...
Income Tax : The Tribunal held that transfer pricing adjustment cannot survive without a final assessment order post-DRP directions. Repeating ...
Income Tax : The Tribunal held that subscription to preference shares cannot be re-characterized as loans in absence of evidence showing sham t...
Income Tax : The tribunal held that the safe harbour limit applies to valuation determined by the DVO, not just stamp duty value. It ruled in f...
Income Tax : The Court held that Tribunal remand is not a fresh reference under transfer pricing law. Hence, limitation expired earlier, entitl...
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...
Fees for Technical Services (FTS) in India’s tax law conflict with DTAAs that include the ‘make available’ clause. This clause requires the transfer of know-how for FTS taxation, leading to extensive litigation over interpretation and applicability.
ITAT Delhi ruled that salary paid to expatriates on local contracts is deductible and that CSR expenditure disallowed under Section 37(1) remains eligible for deduction under Section 80G.
ITAT Delhi directs the exclusion of the Rs. 84.95 lakh Transfer Pricing adjustment from the Book Profits (u/s 115JB), citing the Supreme Court’s ruling in Apollo Tyres Ltd. that the AO cannot tamper with the net profit determined under the Companies Act, except for specified adjustments.
ITAT Hyderabad deletes a ₹10.10 Cr TP adjustment on AE consultancy fees to Virinchi Ltd, holding TPO cannot question commercial expediency of services when ALP is proven.
The ITAT Mumbai has deleted a Rs. 184.75 crore transfer pricing adjustment related to advertising and marketing expenses (AMP). The tribunal ruled that these expenses were not an international transaction, aligning with consistent past judgments and emphasizing that the Revenue failed to prove a formal arrangement between the assessee and its Associated Enterprise (AE).
The Bombay High Court has quashed a penalty order against Man Truck & Bus India Pvt. Ltd., citing a failure to grant a virtual hearing and a flawed assessment basis under an Advanced Pricing Agreement.
Supreme Court dismissed the SLP, affirming that ITAT rightly remanded the case to TPO to reassess ALP of intra-group services, stressing that Section 92C(3) conditions must be examined before adjustments.
The ITAT Bangalore has remanded the transfer pricing case of Andante Foods LLP, directing the firm to provide audited financials of its foreign subsidiary to justify its selection as a tested party.
ITAT directs fresh transfer pricing analysis for UST Global, ruling that tax authorities must apply an upper turnover filter when using a lower one.
Karnataka High Court held that for AY 2014-2015, assessee couldn’t be classified as wholesale trader as both the specified conditions are not satisfied. Accordingly, in terms of notification no. 30/2013 tolerance range of 3% to be adopted.
