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 Delhi deletes transfer pricing adjustment on engineering services for Lummus Technology Heat Transfer BV, citing Delhi High Court rulings.
ITAT Hyderabad upholds Rs 1.33 cr TP adjustment against Hammond Power Solutions for technical/stewardship services, citing insufficient evidence of service delivery.
Read about DCIT Vs Alfa Laval India Pvt Ltd (ITAT Pune): Key findings on Transfer Pricing, rejection of Cost Plus Method, and disallowances for project costs and actuarial gains.
ITAT Delhi rules commission to Amway distributors is not part of AMP expenses for transfer pricing adjustment. Deduction u/s 80G allowed.
Delhi High Court held that Resale Price Method (RPM) is the most appropriate method to determine arm’s length price since assessee purely acts as a distributor and makes no value addition. Thus, appeal of revenue dismissed.
Delhi High Court held that before undertaking a benchmarking of Advertisement, Marketing and Promotion [AMP expenses], it was incumbent upon the TPO to have found that an international transaction had, in fact, occurred. Thus, appeal of revenue dismissed.
CBDT notifies Income Tax (Sixth Amendment) Rules, 2025, introducing safe harbour rules for assessment year 2025-26. Full details of amendment provided.
Advocate Amardeep Soni & Advocate Harsha Soni Gemplus India Pvt. Ltd. Vs ACIT (ITAT Bangalore) A Case Study of ITAT BANGALORE BENCH ‘A’ Gemplus India (P.) Ltd. v. Assistant Commissioner of Income-tax, Circle-11(4), Bangalore [2010] 3 taxmann.com 755 (Bangalore – Trib.) Abstract: The practice of cost allocation and transfer pricing is integral to multinational corporations (MNCs) […]
Learn about income tax exemptions for universities, hospitals, and educational institutions under Section 10 of the Income Tax Act, including Rule 2BBB provisions.
Bangalore ITAT overturns AO’s PE classification of QlikTech India, orders fresh review based on TPO order, addresses TDS and interest issues.
