Income Tax : This article explains how Safe Harbour Rules under the Income-tax Act, 2025 interact with APAs, MAP provisions, and transfer prici...
Income Tax : The framework outlines mandatory disclosures and timelines for opting into safe harbour. Key takeaway: strict compliance is essent...
Income Tax : The article explains how safe harbour rules simplify transfer pricing compliance. It highlights that eligible transactions are acc...
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 : 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 : ITAT Mumbai deleted the transfer pricing adjustment on management fees after finding that identical issues in the assessee’s own...
Income Tax : The ITAT held that transfer pricing adjustment was not justified where the foreign LLC’s income was already offered to tax in In...
Income Tax : ITAT Ahmedabad held that transfer pricing authorities cannot assign a NIL arm’s length price when the assessee has demonstrated ...
Income Tax : The Hyderabad ITAT found contradictions in the TPO’s reasoning for excluding a comparable company due to alleged lack of RPT dat...
Income Tax : Pune ITAT held that once TNMM is accepted for a taxpayer’s aggregated international transactions, the TPO cannot isolate a singl...
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...
ITAT Delhi held that Transfer Pricing Adjustment made by the revenue on account of administrative support services segment deserves to be deleted since services rendered are in nature of intra group services and not stewardship activity.
ITAT observed that applying an upper turnover filter is essential in transfer pricing cases where the assessee’s turnover is much lower. It ordered exclusion of big IT majors from the comparable list and directed fresh computation of ALP.
Delhi High Court held that tax authorities cannot replace projected business valuations with actual results when assessing transfer pricing, emphasizing commercial prudence principle in asset transfers.
Notification 157/2025 sets 1% tolerance for wholesale trading and 3% for all other cases for Arm’s Length Price variation for AY 2025-2026 under the Income-tax Act.
Tribunal held that Netflix India is a limited-risk distributor providing access support services, not a content or technology entrepreneur. Since no copyright or technical licence existed, the ₹445-crore royalty-based transfer pricing adjustment was deleted.
KSCAA urged CBDT to extend due dates for assessees under Section 92E, citing an omission in Circular No. 15/2025 that created inconsistency in tax compliance timelines.
Delhi HC reviews CBDT’s decision to exclude Transfer Pricing (TP) cases from the extended ITR deadline, an unprecedented departure from past practice. The case addresses the arbitrary denial of relief to TP-only assessees, raising concerns over administrative fairness and compliance consistency.
ejecting the Revenue’s approach, the Tribunal held that mere quantum of advertisement or marketing expenses cannot trigger transfer pricing adjustment without demonstrating a direct nexus with a foreign AE.
CBDT Circular extends ITR filing to Dec 10, 2025, and Audit Reports (44AB/12A) to Nov 10, 2025, for audit assessees. TP report deadlines are unchanged.
The CBDT extended the ITR deadline for audited cases (Oct 31 date) but excluded TP audit cases (Nov 30 date). This technical gap means TP deadlines may remain unchanged, requiring an urgent CBDT clarification.
