Income Tax : Explore the Principal Purpose Test (PPT) in international tax law, its impact on treaty benefits, legal uncertainty, and potential...
Income Tax : Learn about income tax exemptions for universities, hospitals, and educational institutions under Section 10 of the Income Tax Act...
Income Tax : Learn about the amendments to Section 92CA concerning references to the Transfer Pricing Officer for determining arm's length pric...
Income Tax : New transfer pricing rules allow arm’s length price (ALP) determinations to apply for two consecutive years, reducing compliance...
Income Tax : Finance Bill 2025 allows multi-year Arm’s Length Price determination for similar transactions, reducing repetitive proceedings i...
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Income Tax : ICAI Releases Exposure Draft Guidance Note On Report Under Section 92E Of Income-Tax Act, 1961 (Transfer Pricing) Based on the la...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 : Advocate Amardeep Soni & Advocate Harsha Soni Gemplus India Pvt. Ltd. Vs ACIT (ITAT Bangalore) A Case Study of ITAT BANGALORE...
Income Tax : Bangalore ITAT overturns AO's PE classification of QlikTech India, orders fresh review based on TPO order, addresses TDS and inter...
Income Tax : ITAT Bangalore sets aside AO's decision in Qlik Tech International AB vs DCIT, addressing PE classification, TDS credit, and tax r...
Income Tax : ITAT Delhi directs inclusion of Magma Advisory Services Ltd. in Honda R&D's comparable list, rejecting TPO's reasons and DR's func...
Income Tax : ITAT Bangalore deletes AO’s protective addition in LM Wind Power case, citing settled MAP proceedings on IT fees and commission ...
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...
Income Tax : Notification No. 46/2023-Income-Tax Dated: 26th June, 2023 regarding deemed arm's length price for assessment year 2023-2024. Le...
ITAT that as long as the charges for hourly services provided by appellant were uniform to AEs and third parties, rejection of CUP method was unwarranted.
Penalties for failing to maintain records of specified domestic transactions. Learn about arm’s length pricing & essential document requirements
The Delhi High Court directs the ITAT to reconsider the exclusion of Onward Technologies Limited (OTL) as a comparable in the transfer pricing study. Detailed analysis and conclusion.
Delhi High Court upheld the exclusion of comparables due to functional dissimilarity and significant turnover differences. Analysis of the PCIT vs. Qualcomm India Pvt Ltd case.
The Income Tax Appellate Tribunal (ITAT) in Pune deleted the penalty in the Jyoti Paper Udyog Ltd Vs. ACIT case due to non-production of Form No. 3CEB under Section 92E.
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.
