Income Tax : Learn how Section 161 of the Income-tax Act, 2025 establishes the arm's length principle for international and specified domestic ...
Income Tax : The article explains how transactions between associated domestic entities exceeding ₹20 crore must comply with arm's length pri...
Income Tax : Taxpayers entering specified domestic transactions exceeding prescribed thresholds must maintain transfer pricing documentation, a...
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 : 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 Delhi held that documentary evidence established receipt of intra-group administrative support services and that the 5% marku...
Income Tax : ITAT held forex loss from ECB and capital transactions is non-operating for TP purposes and directed recomputation of PLI....
Income Tax : ITAT held that increased employee remuneration cannot be disallowed merely because business revenue declined where the expenditure...
Income Tax : The ITAT Pune held that detailed agreements, invoices and supporting records established that management support services were act...
Income Tax : ITAT excluded EDCIL, Just Dial, Info Edge and India Exposition Mart as transfer pricing comparables due to functional differences ...
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...
Supreme Court has asked the finance ministry and Central Board of Direct Taxes (CBDT), the apex body in charge of administering India’s taxation system, to amend transfer pricing, or TP, laws if it wishes to bring domestic transactions under their ambit.
The Hon’ble Supreme Court (Supreme Court), on 1st October 2010, in the case of Maruti Suzuki India Ltd. has directed the Transfer Pricing Officer (TPO) to complete the transfer pricing assessment proceedings without being influenced by the judgment passed by the Delhi High Court. The Delhi High Court had clarified crucial transfer pricing dimensions related to marketing intangibles and provided guidance for ascertaining the arm’s length price under the provisions of Section 92 of the Income Tax Act, 1961 (the Act)
Delhi High Court Ruling: Transfer Pricing – Sec 92 – An important ruling by the Hon’ble High Court wherein it has been held that the methodology to be adopted by the Revenue Authorities for making an adjustment should be equitable and fair, and has ruled on the payment for the use of intangible assets and attributing arm’s length consideration for activities carried out by the licensee, etc. [Maruti Suzuki India Limited – W.P. 6876/2008]
A General Anti-Avoidance Rule (GAAR) was proposed in the Indian tax legislation for the first time in DTC 2009, apart from Specific Anti-avoidance Rules (SAARs) like transfer pricing (TP) provisions, dividend stripping transactions in securities, dis
With the advent of MNCs(Multi National Concerns) a trend has also been adopted by the MNCs to structure their investments and business strategy in such a way that profits are maximized in such jurisdictions where tax rates are low, which give rise to the emerging problem of transfer pricing all over the world.
ITAT Ruling: Transfer Pricing – Sec 92 – While benchmarking a controlled transaction, mere selling of an identical product to unrelated party is not sufficient for applying Comparable Uncontrolled Price (CUP) as the most appropriate method unless reasonable and accurate adjustments on account of economic and market differences can be arrived to determine the arm’s length price. [M/s Intervet India Private Limited – 2010-TIOL-240- ITAT-MUM].
The US and Indian competent tax authorities have reached a negotiated settlement on transfer pricing dispute in respect of certain captive software development units for the financial year 2004-05. The settlement has been reached through the mutual agreement procedure (MAP) mechanism provided in the Indo-US Double Taxation Avoidance Agreement (DTAA), sources said.
The Finance Act, 2001 substituted section 92 with a new section and introduced new sections 92A to 92F in the Income-tax Act, relating to computation of income from an international transaction in order to facilitate the computation of reasonable, fair and equitable profits and tax in India in the case of businesses carried on by multinational companies. The transfer pricing provisions are in line with those stipulated by OECD. However there is a difference that the Indian legislation does not permit the use of unspecified method to compute arms length price as permitted in OECD guidelines.
The Institute of Chartered Accountants of India (ICAI) plans to familiarise its members, especially the partners of small auditing firms, with the best transfer pricing methods to help them take up larger audit assignments involving companies that have overseas businesses.
The CBDT and OECD are jointly holding an International seminar on transfer pricing at Vigyan Bhawan, New Delhi, India from 17th to 19th February 2010. Shri Pranab Mukherjee, Finance Minister of India, will inaugurate the seminar. Shri. S.S. Palanimanickam Minister of state for Finance (Revenue); Shri. Sunil Mitra, Secretary (Revenue); Shri. S.S.N. Moorthy, Chairman CBDT; Mrs. Caroline Silberztein, Head of transfer pricing unit OECD;
