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...
ITAT Bangalore rules against using high-turnover IT giants as comparables for smaller captive service providers in transfer pricing, citing scale and brand value differences.
Chartered Accountants Association, Ahmedabad requests extension of ITR and audit due dates for AY 2025-26 citing compressed timelines and compliance challenges.
The ITAT granted Lowe’s India partial relief, allowing an 80G deduction for CSR donations while correcting MAT profit and other disallowances. The transfer pricing issue was remanded for a fresh review.
Bangalore ITAT rules large companies like Infosys BPM & Tech Mahindra cannot be comparables for small captive service providers. Loss set-off also directed.
The Mumbai ITAT ruled that MLI provisions cannot be applied to deny treaty benefits under the India–Ireland DTAA without a specific notification under Section 90(1) of the Income Tax Act.
ITAT Bangalore mandates working capital adjustments and excludes functionally different comparables in a transfer pricing case, directing a fresh benchmarking analysis.
ITAT Delhi has directed Assessing Officer to amend assessment for Richemont India, reducing a Rs 33.95 crore transfer pricing addition to nil.
The Karnataka High Court upheld the exclusion of Universal Print System and BNR Udhyog as comparables in a transfer pricing case involving Robert Bosch.
The ITAT Delhi has remanded the transfer pricing case of Stryker India Pvt. Ltd., directing the exclusion of one comparable and inclusion of another, and allowing for the netting of payables and receivables.
ITAT Delhi deleted transfer pricing adjustments made to Sony India, ruling that the intensity adjustment is an invalid substitute for the Brightline Test and that royalty payments were commercially justified.
