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Transfer Pricing

Latest Articles


India Transfer Pricing- Due Dates for Compliance for Tax Year 2026-27

Income Tax : The update outlines revised compliance forms, timelines, and penalties under the new rules. It highlights a structured transition ...

April 17, 2026 297 Views 0 comment Print

Transfer Pricing MAM Selection: Germany–India Subsidiary Case (TNMM Approach)

Corporate Law : The issue was identifying the correct transfer pricing method for intercompany transactions. The conclusion holds that TNMM is app...

April 14, 2026 135 Views 0 comment Print

Netflix India Wins ₹444 Crore Transfer Pricing Fight

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...

April 13, 2026 351 Views 0 comment Print

Transfer Pricing under Income Tax Act: ALP, AEs & Compliance Framework

Income Tax : This explains the new block assessment mechanism allowing ALP to apply across multiple years. It emphasizes reduced disputes and s...

April 9, 2026 666 Views 0 comment Print

Form No. 48: Transfer Pricing Certification under Income-tax Act, 2025

Income Tax : The issue concerns replacement of Form 3CEB with a new reporting framework. The reform mandates structured reporting with enhanced...

April 6, 2026 996 Views 0 comment Print


Latest News


Record 219 APAs Signed Due to Rising Need for Transfer Pricing Certainty

Income Tax : CBDT signed a record number of APAs to provide clarity on transfer pricing and reduce disputes. The framework ensures advance dete...

April 1, 2026 228 Views 0 comment Print

KSCAA Seeks Parity in ITR Due Date Extension for Transfer Pricing Assessees

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...

November 3, 2025 483 Views 0 comment Print

CA Association Seeks Extension for ITR, Tax and TP Audit Dates

CA, CS, CMA : Chartered Accountants Association, Ahmedabad requests extension of ITR and audit due dates for AY 2025-26 citing compressed timeli...

September 10, 2025 8139 Views 1 comment Print

Tolerance Range for Transfer Pricing Notified for AY 2024-25

Income Tax : CBDT sets transfer pricing tolerance range at 1% for wholesale trading and 3% for other transactions for AY 2024-25, providing cla...

October 30, 2024 2199 Views 0 comment Print

Budget 2024: TPO can evaluate SDTs not reported by taxpayers

Income Tax : From April 2025, TPOs can determine ALP for SDTs not initially referred or reported. This ensures accurate adjustments and complia...

July 26, 2024 1044 Views 0 comment Print


Latest Judiciary


Companies with significantly higher turnover are not comparable: ITAT Bangalore

Income Tax : The issue was whether high-turnover companies can be compared with a smaller software service provider. The Tribunal held that com...

April 2, 2026 318 Views 0 comment Print

Missed DRP timeline kills TP addition; ₹288 Cr share capital upheld

Income Tax : The Tribunal held that transfer pricing adjustment cannot survive without a final assessment order post-DRP directions. Repeating ...

March 27, 2026 426 Views 0 comment Print

ITAT Mumbai Rejects TP Adjustment as Preference Shares Cannot Be Treated as Loans Without Evidence

Income Tax : The Tribunal held that subscription to preference shares cannot be re-characterized as loans in absence of evidence showing sham t...

March 24, 2026 411 Views 0 comment Print

ITAT Allows 10% Safe Harbour on DVO Valuation Due to Estimation Nature of Property Values

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...

March 21, 2026 414 Views 0 comment Print

United Spirits Case: Remand in TP Case Does Not Extend Section 153 Limitation

Income Tax : The Court held that Tribunal remand is not a fresh reference under transfer pricing law. Hence, limitation expired earlier, entitl...

March 21, 2026 273 Views 0 comment Print


Latest Notifications


Income Tax ALP Tolerance Range for AY 2025-26 Notified

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...

November 6, 2025 4782 Views 0 comment Print

Amendment of Safe Harbour Rules for AY 2025-26 under Section 92CB

Income Tax : CBDT notifies Income Tax (Sixth Amendment) Rules, 2025, introducing safe harbour rules for assessment year 2025-26. Full details o...

March 25, 2025 4596 Views 0 comment Print

Tolerance Range for Arm’s Length Price in FY 2024-25

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...

October 18, 2024 3171 Views 0 comment Print

Income-tax (Twenty-Ninth Amendment) Rules, 2023

Income Tax : Stay informed on the latest Income Tax Rule changes with Notification No. 104/2023 by the Ministry of Finance. Learn about amendme...

December 19, 2023 4500 Views 0 comment Print

CBDT extends applicability of Safe Harbour rules to AY 2023-24

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...

August 9, 2023 12663 Views 0 comment Print


Budget 2024: TPO can evaluate SDTs not reported by taxpayers

July 26, 2024 1044 Views 0 comment Print

From April 2025, TPOs can determine ALP for SDTs not initially referred or reported. This ensures accurate adjustments and compliance with new regulations.

Payment by Indian Entity to AE Abroad Not ‘FTS’ if No Technical Skill Provided: Bangalore ITAT

July 4, 2024 804 Views 0 comment Print

Learn how ITAT Bangalore ruled in favor of Herbalife India on technical service payments, clarifying FTS under India-USA DTAA. Detailed analysis and full judgment inside.

Demystifying Transfer Pricing

June 29, 2024 1809 Views 0 comment Print

Learn about transfer pricing, its importance, methods, documentation, penalties for non-compliance, and advanced pricing agreements in India.

Benchmarking Managerial Compensation in UAE: Understanding Transfer Pricing Framework

June 25, 2024 4791 Views 0 comment Print

Understand the UAE’s transfer pricing framework and benchmarks for managerial compensation under the new corporate tax law. Ensure compliance with Article 36 requirements.

ITAT Directs 6% SBI Rate on Delayed Payments in International Transactions

June 21, 2024 675 Views 0 comment Print

Explore the ITAT Hyderabad’s decision on interest as an international transaction in Clinasia Labs Pvt Ltd vs ITO case. Detailed analysis and conclusions provided.

RPM is most appropriate method When No Value Addition Before Resale

June 16, 2024 1476 Views 0 comment Print

ITAT Delhi rules RPM as the best method for benchmarking solar goods purchases in the D Light Energy P. Ltd. vs Assessing Officer case. Read the detailed analysis.

ITAT Rulings on TP Adjustments, ESOP Expenses & Section 14A Disallowance

June 11, 2024 1146 Views 0 comment Print

Tribunal upholds CIT(A) decisions in DCIT Vs Astral Limited case, offering key insights on TP adjustments, ESOP expenses, and Section 14A disallowance.

Subsidiary would only be deemed a PE if it satisfies specific tests outlined in DTAA

June 9, 2024 1512 Views 0 comment Print

Delhi High Court quashes reassessment notices by DCIT after TPO settles arm’s length remuneration issue. Detailed analysis of Progress Rail Locomotive Inc. vs DCIT case.

Taxation – The Game of Life – Transfer Pricing & International Taxation

June 2, 2024 1548 Views 0 comment Print

Explore the complexities of international taxation and transfer pricing, crucial for multinational enterprises. Learn about associated enterprises, specified domestic transactions, and the methods for determining arm’s length prices.

TPO fails to Apply Industry Filter while Determining ALP of Interest: ITAT Deletes addition

May 31, 2024 810 Views 0 comment Print

ITAT Delhi dismisses DCIT’s appeal against DLF Urban Pvt. Ltd. TPO failed to apply industry filter for ALP of interest, resulting in the deletion of Rs. 6.29 crores addition.

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