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 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 : The Hyderabad ITAT found contradictions in the TPO’s reasoning for excluding a comparable company due to alleged lack of RPT dat...
Income Tax : Pune ITAT held that once TNMM is accepted for a taxpayer’s aggregated international transactions, the TPO cannot isolate a singl...
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 remands Orange Business Services India’s transfer pricing case, ordering separate benchmarking for IT and ITES segments based on consistency and directing the use of the headcount method for expense allocation.
Assessee then filed an appeal before Tribunal. It was held that assessee had included net gain of ₹17.02 crore from foreign currency transactions and translations in its operating income, but DRP had rejected the claim.
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.
