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Transfer Pricing

Latest Articles


Demystifying Transfer Pricing

CA, CS, CMA : Learn about transfer pricing, its importance, methods, documentation, penalties for non-compliance, and advanced pricing agreement...

June 29, 2024 396 Views 0 comment Print

Benchmarking Managerial Compensation in UAE: Understanding Transfer Pricing Framework

Income Tax : Understand the UAE's transfer pricing framework and benchmarks for managerial compensation under the new corporate tax law. Ensure...

June 25, 2024 690 Views 0 comment Print

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

Income Tax : Explore the complexities of international taxation and transfer pricing, crucial for multinational enterprises. Learn about associ...

June 2, 2024 852 Views 0 comment Print

Key takeaways from an M&A perspective from the commentary on Global Anti-Base Erosion Model Rules, 2023

Income Tax : Discover key insights on Global Anti-Base Erosion Model Rules (GloBE) for M&A strategies. Learn about Income Inclusion and Underta...

May 27, 2024 426 Views 0 comment Print

Digital Taxation: Strategies and Implications for Global Economies

Income Tax : Delve into the complexities of digital taxation, exploring its evolution, significance, and global responses. Learn about fair ta...

April 30, 2024 777 Views 0 comment Print


Latest News


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 12234 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Draft Guidance Note on Transfer Pricing Report – Section 92E

Income Tax : ICAI Releases Exposure Draft Guidance Note On Report Under Section 92E Of Income-Tax Act, 1961 (Transfer Pricing) Based on the la...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 25824 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 11652 Views 1 comment Print

Request to extend due dates of Tax Audit Report & Other forms

Income Tax : Voice Of CA has made a Request for Extension of specified date of filing Tax Audit Report and other forms falling due on or before...

January 7, 2022 27855 Views 12 comments Print

Request to Extend Due Dates for filing Tax & Transfer Pricing Audit

Income Tax : Chamber of Tax Consultants has made a Request for Extension of Due Dates for filing Tax Audit and Transfer Pricing Reports to Smt....

January 7, 2022 8577 Views 1 comment Print


Latest Judiciary


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

Income Tax : Learn how ITAT Bangalore ruled in favor of Herbalife India on technical service payments, clarifying FTS under India-USA DTAA. Det...

July 4, 2024 327 Views 0 comment Print

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

Income Tax : Explore the ITAT Hyderabad's decision on interest as an international transaction in Clinasia Labs Pvt Ltd vs ITO case. Detailed a...

June 21, 2024 345 Views 0 comment Print

RPM is most appropriate method When No Value Addition Before Resale

Income Tax : ITAT Delhi rules RPM as the best method for benchmarking solar goods purchases in the D Light Energy P. Ltd. vs Assessing Officer ...

June 16, 2024 855 Views 0 comment Print

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

Income Tax : Tribunal upholds CIT(A) decisions in DCIT Vs Astral Limited case, offering key insights on TP adjustments, ESOP expenses, and Sect...

June 11, 2024 354 Views 0 comment Print

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

Income Tax : Delhi High Court quashes reassessment notices by DCIT after TPO settles arm's length remuneration issue. Detailed analysis of Prog...

June 9, 2024 609 Views 0 comment Print


Latest Notifications


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 2847 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 10524 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 1500 Views 0 comment Print

Tolerance Band for AY 2022-23 in case of wholesale trading & others

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...

June 28, 2022 2328 Views 0 comment Print

Safe Harbour rules for AY 2022-2023 – Income tax Act, 1961

Income Tax : Safe Harbour rules for AY 2022 2023 | Income tax Act, 1961 | Notification No. 66/2022-Income-Tax | Dated: 17th June, 2022 |  CBDT...

June 17, 2022 13653 Views 0 comment Print


Key takeaways from an M&A perspective from the commentary on Global Anti-Base Erosion Model Rules, 2023

May 27, 2024 426 Views 0 comment Print

Discover key insights on Global Anti-Base Erosion Model Rules (GloBE) for M&A strategies. Learn about Income Inclusion and Undertaxed Profits Rules, and their impact on corporate restructuring.

Letters of Comfort will construe as an International Transaction u/s 92B

May 13, 2024 558 Views 0 comment Print

Issuance Of Letters Of Comfort/Support will Construe As International Transaction U/s 92B considering corporate guarantee issued by assessee could not be compared with the letters of comfort and therefore agreed with the computation of arm’s length rate of 0.04%.

Manufacturing Segment Transaction Benchmarking: ITAT Upholds TNMM Method Over CUP

May 10, 2024 291 Views 0 comment Print

Read the full text of ITAT Mumbai’s order in the case of LANXESS India Pvt Ltd vs DCIT, upholding TNMM method over CUP for benchmarking export transactions under manufacturing segment.

Delhi HC ruling on transfer pricing provisions concerning intra-group services

May 8, 2024 393 Views 0 comment Print

Read the Delhi High Court judgment on PCIT vs Mercer Consulting India Pvt. Ltd. regarding transfer pricing provisions and intra-group services.

Consider Volume Discount & Geographic Price Variation in TP Adjustment: ITAT Ahmedabad

May 8, 2024 225 Views 0 comment Print

Ahmedabad ITAT’s order in Atul Limited vs DCIT case discusses TP adjustments, volume discount, geography adjustments, and more. Detailed analysis provided.

Ahmedabad ITAT Clarifies Letter of Credit vs. Bank Guarantee in Transfer Pricing Dispute

May 8, 2024 861 Views 0 comment Print

In a detailed analysis of Axis Bank Limited Vs ACIT case, Ahmedabad ITAT explains the difference between a Letter of Credit and Corporate Guarantee, resolving disallowance disputes.

Bullion Purchases: LBMA Rates vs. KITCO and Reuters for ALP

May 6, 2024 255 Views 0 comment Print

ITAT considered the justification provided by the assessee, which referenced KITCO and Reuters databases for determining transaction prices. However, the Transfer Pricing Officer (TPO) argued that the London Bullion Market Association (LBMA) should be the primary source for estimating bullion trading prices.

ITAT Directs TPO/AO to Delete Adjustment on Export Commission Payment ALP

May 5, 2024 213 Views 0 comment Print

In the case of Honda Motorcycle & Scooter India Pvt Ltd vs. ACIT, ITAT Delhi directed the Transfer Pricing Officer (TPO) and Assessing Officer (AO) to delete the adjustment made on account of the arm’s length price (ALP) of export commission payment.

Digital Taxation: Strategies and Implications for Global Economies

April 30, 2024 777 Views 0 comment Print

Delve into the complexities of digital taxation, exploring its evolution, significance, and global responses. Learn about fair taxation, revenue generation, and the quest for international cooperation.

AO Must Adhere to TPO’s ALP in International Transactions: Delhi HC

April 11, 2024 483 Views 0 comment Print

Delhi High Court rules AO can’t deviate from Transfer Pricing Officer’s determined Arm’s Length Price (ALP) in international transactions, upholding assessee’s writ petition.

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