Income Tax : This article explains how Safe Harbour Rules under the Income-tax Act, 2025 interact with APAs, MAP provisions, and transfer prici...
Income Tax : The framework outlines mandatory disclosures and timelines for opting into safe harbour. Key takeaway: strict compliance is essent...
Income Tax : The article explains how safe harbour rules simplify transfer pricing compliance. It highlights that eligible transactions are acc...
Income Tax : The update outlines revised compliance forms, timelines, and penalties under the new rules. It highlights a structured transition ...
Corporate Law : The issue was identifying the correct transfer pricing method for intercompany transactions. The conclusion holds that TNMM is app...
Income Tax : CBDT signed a record number of APAs to provide clarity on transfer pricing and reduce disputes. The framework ensures advance dete...
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...
CA, CS, CMA : Chartered Accountants Association, Ahmedabad requests extension of ITR and audit due dates for AY 2025-26 citing compressed timeli...
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 : ITAT Mumbai deleted the transfer pricing adjustment on management fees after finding that identical issues in the assessee’s own...
Income Tax : The ITAT held that transfer pricing adjustment was not justified where the foreign LLC’s income was already offered to tax in In...
Income Tax : ITAT Ahmedabad held that transfer pricing authorities cannot assign a NIL arm’s length price when the assessee has demonstrated ...
Income Tax : The Hyderabad ITAT found contradictions in the TPO’s reasoning for excluding a comparable company due to alleged lack of RPT dat...
Income Tax : Pune ITAT held that once TNMM is accepted for a taxpayer’s aggregated international transactions, the TPO cannot isolate a singl...
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...
Income Tax : CBDT notifies Income Tax (Sixth Amendment) Rules, 2025, introducing safe harbour rules for assessment year 2025-26. Full details o...
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...
The Tribunal restored issues relating to comparable company margins and working capital adjustment after finding that the assessee’s submissions required verification. The appeal was allowed for statistical purposes.
Delhi ITAT Restricts Corporate Guarantee Fee to 0.30% After Finding Actual Interest Saving Was Only 0.60%; Holds TP Adjustment Must Reflect Real Benefit From Corporate Guarantee.
ITAT Delhi deleted transfer pricing adjustments after holding that retail and after-sales businesses could not be compared with wholesale trading to OEMs. The Tribunal ruled that comparables must satisfy functional and market similarity under Rule 10B(2).
The Ahmedabad ITAT held that goodwill arising from a High Court-approved amalgamation qualified as an intangible asset eligible for depreciation under Section 32(1)(ii). The Tribunal followed earlier decisions in the assessee’s own case.
ITAT Hyderabad held that assessment orders passed pursuant to earlier remand directions were barred by limitation under Section 153. The Tribunal set aside all consequential transfer pricing assessment orders dated 06.12.2024.
ITAT Mumbai held that a company engaged in publishing platforms, software solutions, and product development could not be compared with a limited-risk captive ITES service provider. Exclusion of the comparable eliminated the transfer pricing adjustment.
Tribunal found the DRP’s order cryptic and lacking proper analysis on similarity of business activities between the assessee and selected comparables. Fresh examination was directed regarding comparability and ALP computation.
The Tribunal ruled that margins agreed under a Bilateral Advance Pricing Agreement may be used for non-covered AEs when transactions are functionally similar. The decision emphasized consistency and the lack of separate benchmarking by the TPO.
Delhi ITAT directed exclusion of a comparable company engaged in video conferencing solutions after noting that the DRP had already found it functionally incomparable to the assessee’s software distribution business.
The Delhi ITAT held that advertisement and marketing expenses could not be treated as an international transaction without evidence of an arrangement with the associated enterprise. The Tribunal deleted the transfer pricing adjustment and rejected the application of the Bright Line Test.
