Income Tax : Learn about the amendments to Section 92CA concerning references to the Transfer Pricing Officer for determining arm's length pric...
Income Tax : New transfer pricing rules allow arm’s length price (ALP) determinations to apply for two consecutive years, reducing compliance...
Income Tax : Finance Bill 2025 allows multi-year Arm’s Length Price determination for similar transactions, reducing repetitive proceedings i...
Finance : The Finance Bill 2025 proposes multi-year ALP determination to reduce compliance burdens in transfer pricing. Learn about its fram...
Income Tax : Karnataka HC ruled that omission of Section 92BA(i) invalidates its application to domestic transactions, limiting transfer pricin...
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 : What is the procedure to approve Form 3CEB? Form uploaded by CA shall be available under For your action tab in Taxpayer’s Workl...
Income Tax : ICAI Releases Exposure Draft Guidance Note On Report Under Section 92E Of Income-Tax Act, 1961 (Transfer Pricing) Based on the la...
Income Tax : Association for Corporate Advisers and Executives (ACAE) made a Request for Extension of Due Dates for filing Tax Audit and Transf...
Income Tax : It was held that transactions and FAR of assessee were similar to AY 2021-22 and as per the records brought to our notice, there...
Income Tax : Respondent/assessee is a Irish company. It accordingly claimed benefits of the India-Ireland DTAA. ADIR is a wholly owned subsidia...
Income Tax : In the matter above-mentioned ITAT partly allowed the appeal filed by the assessee by remanded it back to file of TPO after consid...
Corporate Law : Delhi HC rules that SEB rates, not IEX rates, determine the market price of electricity in transfer pricing cases, dismissing Reve...
Income Tax : ITAT Delhi clarifies tax treatment for Motricity India: No levy on notional income or closure costs. Insights on Transfer Pricing ...
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...
Income Tax : Notification No. 46/2023-Income-Tax Dated: 26th June, 2023 regarding deemed arm's length price for assessment year 2023-2024. Le...
Income Tax : In exercise of the powers conferred by the third proviso to sub-section (2) of section 92C of the Income-tax Act, 1961 (43 of 1961...
ITAT Delhi held that when the transaction between the assessee and its Indian AE is found to be at arm’s length, no further attribution of profit can be made to the dependent agent PE in India.
Calcutta High Court held that mere usage of foreign word does not make it automatic to fall within the ambit of an international transaction.
Philips India Ltd. vs ACIT (ITAT Kolkata) In many cases, licensed manufacturers operate as risk-bearing entrepreneurs, and there is no existence of an ‘agreement’ or ‘arrangement’ or ‘understanding’ with the AE regarding AMP expenditure, the initial onus is on the revenue to show that there is an international transaction for AMP spend. The mere fact […]
ITAT Ahmedabad held that arms length interest rate for loan advanced to foreign subsidiary by Indian company should be computed based on market determined interest rate applicable to currency in which loan has to be repaid.
Learn why the TNM method may not be suitable for determining the Arms Length Price (ALP) in capital goods purchase transactions under transfer pricing regulations in India. Understand the legal perspectives and recent case decisions.
Understand the differences between the UN and OECD Model Tax Conventions and their application in Indian tax treaties. Dive into article-by-article comparisons and India’s unique tax treaty policies.
Understand the intricacies of Transfer Pricing regulations in the UAE with an overview of the CT Law, including the Arm’s Length Principle, Related Parties, Payments to Connected Persons, and Transfer Pricing Documentation requirements.
OECD/G20 Inclusive Framework (IF) on BEPS released technical guidance to assist governments with implementation of the GMT, which will ensure Multi-National Entities (MNEs) will be subject to a 15% effective minimum tax rate.
Section 92C(1) of Act, contemplates that arms length price in relation to an international transaction shall be determined by comparable uncontrolled price method; resale price method; cost plus method; profit split method; transactional net margin method or such other method as may be prescribed by Board.
ITAT Delhi held that as no adjustment on transfer pricing issue would subsist and therefore there is no question of penalty u/s. 271(1)(c) of the Income Tax Act on such addition.
