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...
Section 144C of IT Act, 1961 was brought through Finance Act, 2009 & introduced for orderly assessment with respect to the international tax case along with transfer pricing. Under this after serving a notice under it a draft assessment order would be given under which recipient shall receive chance of representation during dispute redressal for assessment before such assessment being made final.
Delhi High Court upheld the ITAT’s decision, concluding that the comparability analysis must focus on functional similarity rather than strict product comparability, and that certain disallowances made by the Assessing Officer were unjustified.
Understand penalties for under-reporting and misreporting of income in transfer pricing adjustments, as per the Income Tax Act 1961.
Chapter X of the Income Tax Act applies solely to transactions with Associated Enterprises (AEs), excluding non-AE transactions from transfer pricing provisions.
Delhi High Court remands Alcatel Lucent’s transfer pricing case to ITAT, questioning selection of comparables in ALP determination. Detailed review of objections awaited.
Delhi High Court judgment on Cadence Design’s appeal against the ITAT order regarding transfer pricing comparables. Key findings on ALP determination and comparability.
ITAT Delhi remands JCB India Ltd.’s ₹166.09 crore TP adjustment for non-UK royalty payments to TPO for fresh consideration.
CBDT sets transfer pricing tolerance range at 1% for wholesale trading and 3% for other transactions for AY 2024-25, providing clarity to taxpayers.
Revenue authorities lack jurisdiction to question the business decisions or commercial wisdom of taxpayers in transfer pricing cases, ITAT rulings emphasize.
CBDT sets 1% tolerance for wholesale trading and 3% for other cases under Section 92C for FY 2024-25. No adverse effects from retrospective application.
