Income Tax : Learn about income tax exemptions for universities, hospitals, and educational institutions under Section 10 of the Income Tax Act...
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 : 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Income Tax : ICAI Releases Exposure Draft Guidance Note On Report Under Section 92E Of Income-Tax Act, 1961 (Transfer Pricing) Based on the la...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 : Advocate Amardeep Soni & Advocate Harsha Soni Gemplus India Pvt. Ltd. Vs ACIT (ITAT Bangalore) A Case Study of ITAT BANGALORE...
Income Tax : Bangalore ITAT overturns AO's PE classification of QlikTech India, orders fresh review based on TPO order, addresses TDS and inter...
Income Tax : ITAT Bangalore sets aside AO's decision in Qlik Tech International AB vs DCIT, addressing PE classification, TDS credit, and tax r...
Income Tax : ITAT Delhi directs inclusion of Magma Advisory Services Ltd. in Honda R&D's comparable list, rejecting TPO's reasons and DR's func...
Income Tax : ITAT Bangalore deletes AO’s protective addition in LM Wind Power case, citing settled MAP proceedings on IT fees and commission ...
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...
3F Industries Limited Vs ACIT (ITAT Visakhapatnam) The ALP is to be determined on an international transaction ie., on the international loan and not for the domestic loan. Therefore, the comparable in respect of foreign currency loan in international market is LIBOR based and which is internationally recognized and adopted. In the assessee’s own case […]
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ITAT held that high turnover is a ground to exclude a company from the list of comparable companies in determining ALP, held that there were contrary views on the issue and hence the view favourable to the Assessee laid down in the case of Pentair Water (supra) should be adopted.
Toyota Kirloskar Motor (P) Ltd Vs ACIT (ITAT Bangalore) The Appellant submits the in its own case for AY 2003-04, the Honourable Bangalore Tribunal has accepted that TP adjustment has to restricted to AE transactions. Further, in Appellants own case for AY 2013-14 [ITA No.2016/Bang/2018, dated 18.08.2021], the Honourable Bangalore Tribunal has upheld the action […]
ITAT Delhi held that adoption of Comparable Uncontrolled Price (CUP) method for determining Arm’s Length Price (ALP) of the international transaction is unjustified.
ITAT Mumbai held that as per section 92CA (3A) of the Income Tax Act Transfer Pricing Officer (TPO) is required to pass an order within a period of 60 days prior to the date of completion of assessment as per section 153 of the Income Tax Act. Order passed after the date will be barred by limitation.
Dive into the latest developments on the Global Minimum Tax and BEPS as the international community progresses swiftly in implementing the two-pillar solution. Explore the OECD’s public consultations on Pillar One’s Digital Services Taxes and compliance aspects of Pillar Two. Understand the draft Multilateral Convention provisions aimed at removing existing DSTs and achieving stability in the international tax architecture.
DRP is not empowered to set aside any proposed variation or issue any direction under Section 144C(5) for further enquiry for passing the assessment order and therefore, the disallowance proposed under Section 37 (1) of the Act was without jurisdiction.
ITAT Mumbai held that London Inter-Bank Offered Rate (LIBOR) cannot always be the rate at which intra-bank transactions must take place.
Arm’s Length Price of a transaction can be referred to as such price at which the business profits can be maximized commensurating with the functions performed, assets utilized and risk assumed in such transaction including the fundamental criterion of allocating business income/profits in different tax jurisdictions.
