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 rules LRD trading and after-sales services are functionally inseparable for TP. Mechanical segregation rejected; TNMM must be applied at the entity level on an aggregated basis.
The Karnataka High Court affirmed that SEZ units can claim Section 10AA deduction on income enhanced through a voluntary Advance Pricing Agreement (APA) adjustment. The ruling clarifies that the bar under Section 92C(4) applies only to income enhanced by the Assessing Officer, not to voluntary APA compliance.
Delhi High Court held that separate transfer pricing adjustment for AMP was uncalled for given that the distribution business of assessee was already benchmarked separately and the transaction was benchmarked correctly.
in a colourful observation, the Tribunal compared Juniper’s interlinked trading and service activities to the egg-or-chicken story, holding entity-level TNMM appropriate and deleting the TP addition.
The Tribunal held that the expenditure on acquiring 3G spectrum created an intangible asset, allowing the assessee to claim depreciation u/s 32 of the Act. This crucial finding confirms the asset’s depreciable nature for AY 2012-13, preventing its amortization under later or inapplicable tax code sections.
ITAT Delhi dismissed Revenue’s appeal, deleting a ₹2.18 crore Transfer Pricing (TP) adjustment on palm oil imports. Tribunal ruled that taxpayer rightly used Comparable Uncontrolled Price (CUP) method based on Kuala Lumpur Commodity Exchange (KLCE)-derived broker quotes, confirming CUP as the most appropriate method for commodity trading.
Delhi High Court rules in PCIT v. Amadeus India that no Transfer Pricing adjustment is warranted for AMP expenses, citing no ‘international transaction.’ The Court reiterates the Finance Act 2022 amendment to Section 14A is prospective from AY 2022-23, not retrospective, dismissing the Revenue’s appeal for AY 2018-19.
The Delhi High Court dismissed the Revenue’s appeal against Casio India for AY 2017-18, upholding the deletion of a Transfer Pricing adjustment for AMP expenses. The court ruled that the issue was covered by prior judgments, which rejected the Bright Line Test methodology.
The ITAT deleted the entire Rs.3.94 crore Transfer Pricing (TP) adjustment, ruling that three companies involved in product development, distribution, and proprietary software (Kellton, Magnasoft, Interglobe) were functionally dissimilar to a captive software service provider.2 The Tribunal held that excluding these companies brought the assessees margin of within the Arms Length Price (ALP) range.
The Ahmedabad ITAT set aside a ₹1 lakh penalty under Section 271BA, ruling that failure to electronically file the Form 3CEB transfer pricing report was a mere technical and procedural default. Crucially, the report was prepared before the search and later physically filed with the Transfer Pricing Officer (TPO).
