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Transfer Pricing

Latest Articles


Future of International Taxation: OECD Global Minimum Tax

Income Tax : Learn about income tax exemptions for universities, hospitals, and educational institutions under Section 10 of the Income Tax Act...

March 11, 2025 573 Views 0 comment Print

Budget 2025: Transfer Pricing Amendments

Income Tax : Learn about the amendments to Section 92CA concerning references to the Transfer Pricing Officer for determining arm's length pric...

February 4, 2025 1509 Views 0 comment Print

Transfer Pricing Amendments: Multi-Year ALP Determination

Income Tax : New transfer pricing rules allow arm’s length price (ALP) determinations to apply for two consecutive years, reducing compliance...

February 3, 2025 1029 Views 0 comment Print

Transfer Pricing: Multi-Year ALP Determination in Budget 2025 – FAQs

Income Tax : Finance Bill 2025 allows multi-year Arm’s Length Price determination for similar transactions, reducing repetitive proceedings i...

February 2, 2025 696 Views 0 comment Print

Finance Bill 2025: Amendment related to Transfer Pricing

Finance : The Finance Bill 2025 proposes multi-year ALP determination to reduce compliance burdens in transfer pricing. Learn about its fram...

February 1, 2025 1509 Views 0 comment Print


Latest News


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 1134 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 549 Views 0 comment Print

FAQ’s on filing of Income Tax Form 3CEB

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...

October 28, 2022 13743 Views 0 comment Print

Draft Guidance Note on Transfer Pricing Report – Section 92E

Income Tax : ICAI Releases Exposure Draft Guidance Note On Report Under Section 92E Of Income-Tax Act, 1961 (Transfer Pricing) Based on the la...

July 21, 2022 26184 Views 1 comment Print

ACAE Requested due date extension for filing Tax & TP Audit

Income Tax : Association for Corporate Advisers and Executives (ACAE) made a Request for Extension of Due Dates for filing Tax Audit and Transf...

January 7, 2022 11847 Views 1 comment Print


Latest Judiciary


ITAT Hyderabad Upholds Rs 1.33 Crore TP Adjustment on Hammond Power Over Service Fees

Income Tax : ITAT Hyderabad upholds Rs 1.33 cr TP adjustment against Hammond Power Solutions for technical/stewardship services, citing insuffi...

May 5, 2025 150 Views 0 comment Print

Transfer Pricing Methods: Internal CPM: Domestic & Export Market are not comparable

Income Tax : Read about DCIT Vs Alfa Laval India Pvt Ltd (ITAT Pune): Key findings on Transfer Pricing, rejection of Cost Plus Method, and disa...

May 5, 2025 210 Views 0 comment Print

Commission to Amway Distributors Not AMP Expense for Transfer Pricing: ITAT Delhi

Income Tax : ITAT Delhi rules commission to Amway distributors is not part of AMP expenses for transfer pricing adjustment. Deduction u/s 80G a...

May 1, 2025 264 Views 0 comment Print

Resale Price Method most appropriate as assessee acts as distributor and makes no value addition

Income Tax : Delhi High Court held that Resale Price Method (RPM) is the most appropriate method to determine arm’s length price since assess...

April 2, 2025 177 Views 0 comment Print

Existence of International Transaction Must Be Analyzed Before Benchmarking AMP Expense

Income Tax : Delhi High Court held that before undertaking a benchmarking of Advertisement, Marketing and Promotion [AMP expenses], it was incu...

March 31, 2025 87 Views 0 comment Print


Latest Notifications


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 1263 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 1575 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 3783 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 12069 Views 0 comment Print

Deemed Arm’s Length Price for Assessment Year 2023-2024

Income Tax : Notification No. 46/2023-Income-Tax Dated: 26th June, 2023  regarding deemed arm's length price for assessment year 2023-2024. Le...

June 26, 2023 1770 Views 0 comment Print


Comparable cannot be excluded in Absence of Persistent Losses: ITAT Delhi

February 28, 2025 201 Views 0 comment Print

ITAT Delhi directs inclusion of Magma Advisory Services Ltd. in Honda R&D’s comparable list, rejecting TPO’s reasons and DR’s functional disparity claims.

Protective Addition Unsustainable if Substantial Addition is Confirmed or Settled: ITAT Bangalore

February 27, 2025 219 Views 0 comment Print

ITAT Bangalore deletes AO’s protective addition in LM Wind Power case, citing settled MAP proceedings on IT fees and commission payments.

Negative Margins & Functional Differences: ITAT Upholds Comparable Exclusion

February 26, 2025 270 Views 0 comment Print

ITAT Chennai rules that RRB Energy Ltd. cannot be used as a comparable due to negative margins and functional differences in a transfer pricing case.

CPC Erred in denying Loss Carry-Forward to Company Eligible for Extended Due Date U/s. 92E: ITAT Ahmedabad

February 22, 2025 360 Views 0 comment Print

CPC Erred in Denying Loss Carry-Forward by taking wrong due date for company entitled to extended due date under Section 92E of Income Tax Act due to international transactions: ITAT Ahmedabad

ITAT Directs Fresh TP Study for Non-US AEs After MAP Resolution

February 21, 2025 105 Views 0 comment Print

ITAT Bangalore remands case for a fresh TP study, directing TPO to assess the applicability of MAP-determined ALP to transactions with non-US Associated Enterprises.

Relief to Bloomsbury Publishing in Transfer Pricing Case

February 17, 2025 165 Views 0 comment Print

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 was no change in the activities carried out by assessee in the current assessment year and subsequent assessment years.

Indian AE Transactions at Arm’s Length, HC Says No More Attribution

February 13, 2025 162 Views 0 comment Print

Respondent/assessee is a Irish company. It accordingly claimed benefits of the India-Ireland DTAA. ADIR is a wholly owned subsidiary of Adobe Software Trading Company Limited and Adobe Systems Incorporated is the ultimate parent company of ADIR.

Taxpayer Must Provide Comparable Data in Foreign AE Cases:: ITAT remanded matter

February 13, 2025 150 Views 0 comment Print

In the matter above-mentioned ITAT partly allowed the appeal filed by the assessee by remanded it back to file of TPO after considering that assessee didnot submit proper documents before lower authorities.

Budget 2025: Transfer Pricing Amendments

February 4, 2025 1509 Views 0 comment Print

Learn about the amendments to Section 92CA concerning references to the Transfer Pricing Officer for determining arm’s length pricing in international and domestic transactions.

Transfer Pricing Amendments: Multi-Year ALP Determination

February 3, 2025 1029 Views 0 comment Print

New transfer pricing rules allow arm’s length price (ALP) determinations to apply for two consecutive years, reducing compliance burdens for taxpayers.

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