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 Ahmedabad clarifies corporate guarantees as international transactions, yet upholds Adani Ports’ appeal on no arm’s length adjustment, citing no AE benefit.
The Bombay High Court dismissed Revenue’s appeal against Everest Kanto Cylinder Ltd., citing prior judgments on identical transfer pricing issues.
Calcutta High Court dismisses Revenue appeal, affirming ITAT’s deletion of transfer pricing adjustment on corporate guarantee commission at 0.5%.
Bombay High Court dismissed PCIT’s appeal against Manugraph India Ltd., affirming lower interest rates on AE loans and corporate guarantees based on established precedent from Everest Kanto Cyliners Ltd.
ITAT Pune remands Piaggio Vehicles’ transfer pricing dispute on export segmentation, citing need for verification, while upholding corporate guarantee fee allowance based on judicial precedents.
Explore recent ITAT judgments on reassessment validity, 80G exemptions, DTAA interpretation for online education (FTS/Royalty), transfer pricing methodologies, and cash deposit explanations under Section 68.
India’s Finance Act 2025 clarifies Significant Economic Presence (SEP) rules, excluding mere purchase of goods in India for export from tax liability.
ITAT Delhi directs segment-wise ALP, includes Fiberfox comparable, and rejects notional interest on AE dues for Opterna Technologies, remits Section 68 issue.
ITAT Bangalore held that disallowance of entire royalty payment by taking ALP at NIL not justified since there is no change in facts, circumstances or functions and hence principle of consistency should be applied.
Delhi High Court dismisses tax appeal against Wrigley India, affirming AMP expenses not separate international transaction without evidence, citing precedents.
