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...
In pursuance of the changes made by the Finance Bill 2012 bringing specified domestic transactions under the ambit of Transfer Pricing Regulations, CBDT has amended the format of Form 3CEB vide notification number 41 dated 10 June 2013. The said notification also amends Rule 10A, 10AB, 10B, 10C, 10D and 10E.
The Finance Act’ 2012 has introduced Section – 92 CD relating to the Advance Pricing Agreement (APA) which came into force w.e.f. 1st July’ 2012. An Advance Pricing Agreement is an agreement between the taxpayer and the tax authority on the pricing of future related party transactions. The Taxpayer and the tax authority agrees on […]
Notification No. 41/2013 – Income Tax The CBDT has notified vide Notification No. 41 dated 10 June 2013, new Form 3CEB which includes reporting on specified domestic transactions. The said notification also amends Rule 10A, 10AB, 10B, 10C, 10D and 10E. Following are the additional international transactions required to be reported in new Form 3CEB: International transaction(s) in the nature of guarantee
The Transfer Pricing provisions has been introduced in india in the year 2001. Since then it has come a long way. Now, the Finance Act’ 2012 has extended the scope of Transfer Pricing provisions to certain specified domestic transactions and introduced section-92BA in order to bring in certain specified domestic transactions undertaken by the enterprises […]
The Finance Act, 2012 has extended the applicability of provisions of transfer pricing to Specified Domestic Transactions also. As per Sec.92BA “Specified Domestic Transaction “means:- Any expenditure in respect of which payment has been made or is to be made to a person referred to in clause (b) of Sec. 40A(2), Any transaction referred to […]
CA Praveen Boda UN releases official version of ‘UN Practical Manual on Transfer Pricing for Developing Countries’ at New York; Manual was adopted by UN Committee at Geneva session in October 2012; Manual to help mitigate developing countries’ vulnerability to abuse and revenue loss from tax evasion from transfer pricing; Chapter 10 of the Manual […]
In our opinion, the amount representing 2118.84 is towards investment in share capital of the subsidiaries outside India as the transactions are not in the nature of transactions referred to section 92-B of the IT Act and the transfer pricing provisions are not applicable as there is no income.
The existing language of Section E (paragraphs 4.93 through 4.122) would be removed and replaced with the following language. The enumeration of paragraphs of Section F would be adapted accordingly.
The APA rules provide that APA team would also include experts in economics, statistics, law or any other field as may be nominated by the DGIT (IT).Would such experts be included in each and every APA or would the need be analysed on a case to case basis?
To bring about certainty and uniformity with regard to determination of arm’s length price of the international transaction, the Finance Act, 2012 had inserted sections 92CC and 92CD in the Income Tax Act 1961 introducing the provisions of Advance Pricing Agreement (APA). The Ministry of Finance has notified an Advance Pricing Agreement Scheme (Rules 10F […]
