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 : Karnataka HC ruled that omission of Section 92BA(i) invalidates its application to domestic transactions, limiting transfer pricin...
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Income Tax : ICAI Releases Exposure Draft Guidance Note On Report Under Section 92E Of Income-Tax Act, 1961 (Transfer Pricing) Based on the la...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 : Respondent/assessee is a Irish company. It accordingly claimed benefits of the India-Ireland DTAA. ADIR is a wholly owned subsidia...
Income Tax : In the matter above-mentioned ITAT partly allowed the appeal filed by the assessee by remanded it back to file of TPO after consid...
Corporate Law : Delhi HC rules that SEB rates, not IEX rates, determine the market price of electricity in transfer pricing cases, dismissing Reve...
Income Tax : ITAT Delhi clarifies tax treatment for Motricity India: No levy on notional income or closure costs. Insights on Transfer Pricing ...
Income Tax : Karnataka HC decision on transfer pricing adjustments and Section 92BA amendments in the PCIT vs TT Steel Service India Pvt. Ltd. ...
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...
Delhi High Court rules RPM as the best method for ALP in Burberry India transactions. Rejects Revenue’s AMP-based objections, providing clarity on transfer pricing.
Karnataka HC decision on transfer pricing adjustments and Section 92BA amendments in the PCIT vs TT Steel Service India Pvt. Ltd. case.
ITAT Mumbai allows Transfer Pricing determination for Rallis India Ltd. using the ‘Other Method’ instead of CUP. Key points on ALP adjustments and deductions.
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.
