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 Delhi held that television channel and content owner companies could not be compared with a content distribution business. Th...
Income Tax : ITAT Mumbai held that distribution fees paid to associated enterprises could not be treated as royalty. The Tribunal followed earl...
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 : 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...
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).
Delhi ITAT ruled that a negative lien is not a corporate guarantee, quashing the Rs.16.48 Cr transfer pricing adjustment under Section 92B. Negative lien imposes no repayment liability.
The Delhi High Court dismissed the Revenue’s appeals in CIT-1 v. Casio India Co. Pvt. Ltd. for AY 2012-13 and 2013-14, affirming the ITAT’s finding that AMP expenses did not constitute an international transaction warranting separate transfer pricing adjustments.
Fees for Technical Services (FTS) in India’s tax law conflict with DTAAs that include the ‘make available’ clause. This clause requires the transfer of know-how for FTS taxation, leading to extensive litigation over interpretation and applicability.
ITAT Delhi ruled that salary paid to expatriates on local contracts is deductible and that CSR expenditure disallowed under Section 37(1) remains eligible for deduction under Section 80G.
ITAT Delhi directs the exclusion of the Rs. 84.95 lakh Transfer Pricing adjustment from the Book Profits (u/s 115JB), citing the Supreme Court’s ruling in Apollo Tyres Ltd. that the AO cannot tamper with the net profit determined under the Companies Act, except for specified adjustments.
ITAT Hyderabad deletes a ₹10.10 Cr TP adjustment on AE consultancy fees to Virinchi Ltd, holding TPO cannot question commercial expediency of services when ALP is proven.
The ITAT Mumbai has deleted a Rs. 184.75 crore transfer pricing adjustment related to advertising and marketing expenses (AMP). The tribunal ruled that these expenses were not an international transaction, aligning with consistent past judgments and emphasizing that the Revenue failed to prove a formal arrangement between the assessee and its Associated Enterprise (AE).
The Bombay High Court has quashed a penalty order against Man Truck & Bus India Pvt. Ltd., citing a failure to grant a virtual hearing and a flawed assessment basis under an Advanced Pricing Agreement.
