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...
Supreme Court dismissed the SLP, affirming that ITAT rightly remanded the case to TPO to reassess ALP of intra-group services, stressing that Section 92C(3) conditions must be examined before adjustments.
The ITAT Bangalore has remanded the transfer pricing case of Andante Foods LLP, directing the firm to provide audited financials of its foreign subsidiary to justify its selection as a tested party.
ITAT directs fresh transfer pricing analysis for UST Global, ruling that tax authorities must apply an upper turnover filter when using a lower one.
Karnataka High Court held that for AY 2014-2015, assessee couldn’t be classified as wholesale trader as both the specified conditions are not satisfied. Accordingly, in terms of notification no. 30/2013 tolerance range of 3% to be adopted.
ITAT Bangalore rules against using high-turnover IT giants as comparables for smaller captive service providers in transfer pricing, citing scale and brand value differences.
Chartered Accountants Association, Ahmedabad requests extension of ITR and audit due dates for AY 2025-26 citing compressed timelines and compliance challenges.
The ITAT granted Lowe’s India partial relief, allowing an 80G deduction for CSR donations while correcting MAT profit and other disallowances. The transfer pricing issue was remanded for a fresh review.
Bangalore ITAT rules large companies like Infosys BPM & Tech Mahindra cannot be comparables for small captive service providers. Loss set-off also directed.
The Mumbai ITAT ruled that MLI provisions cannot be applied to deny treaty benefits under the India–Ireland DTAA without a specific notification under Section 90(1) of the Income Tax Act.
ITAT Bangalore mandates working capital adjustments and excludes functionally different comparables in a transfer pricing case, directing a fresh benchmarking analysis.
