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Transfer Pricing

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Safe Harbour Rules under New Income Tax Act, 2025 & Rules, 2026- Part III

Income Tax : This article explains how Safe Harbour Rules under the Income-tax Act, 2025 interact with APAs, MAP provisions, and transfer prici...

May 7, 2026 1122 Views 0 comment Print

Safe Harbour Rules under New Income Tax Act, 2025 & Rules, 2026- Part II

Income Tax : The framework outlines mandatory disclosures and timelines for opting into safe harbour. Key takeaway: strict compliance is essent...

May 1, 2026 1107 Views 0 comment Print

Safe Harbour Rules under New Income Tax Act, 2025 & Rules, 2026: Part I

Income Tax : The article explains how safe harbour rules simplify transfer pricing compliance. It highlights that eligible transactions are acc...

April 28, 2026 6453 Views 0 comment Print

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 1371 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 342 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 402 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 543 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 8184 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 2403 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 1104 Views 0 comment Print


Latest Judiciary


ITAT Deletes Management Fee TP Adjustment as Issue Was Already Decided in Earlier Years

Income Tax : ITAT Mumbai deleted the transfer pricing adjustment on management fees after finding that identical issues in the assessee’s own...

June 8, 2026 117 Views 0 comment Print

No TP Adjustment Allowed if Foreign LLC Income Was Already Taxed in India: ITAT Delhi

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...

June 8, 2026 153 Views 0 comment Print

TP Adjustment Quashed as Benefit Test Cannot Justify NIL ALP After Service Receipt Is Established

Income Tax : ITAT Ahmedabad held that transfer pricing authorities cannot assign a NIL arm’s length price when the assessee has demonstrated ...

June 8, 2026 99 Views 0 comment Print

ITAT Remands TP Adjustment Issue as RPT Filter Was Not Properly Verified

Income Tax : The Hyderabad ITAT found contradictions in the TPO’s reasoning for excluding a comparable company due to alleged lack of RPT dat...

June 5, 2026 111 Views 0 comment Print

Pune ITAT Deletes ₹5.67 Crore TP Adjustment; TPO Cannot Cherry-Pick One Transaction While Accepting TNMM for Others

Income Tax : Pune ITAT held that once TNMM is accepted for a taxpayer’s aggregated international transactions, the TPO cannot isolate a singl...

June 3, 2026 198 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 5121 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 4971 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 3357 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 4650 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 12819 Views 0 comment Print


UAE Transfer Pricing Compliance Dates

July 31, 2024 2295 Views 0 comment Print

Discover the key compliance dates for UAE transfer pricing regulations under the new corporate tax law effective from 1 June 2023. Learn more now!

Transfer Pricing Compliance Chart For FY 2023-24 (AY 2024-25)

July 30, 2024 41754 Views 0 comment Print

India’s Transfer Pricing regulations for FY 2023-24 (AY 2024-25) – This detailed chart lists key activities, legal sections, required forms, and deadlines for easy reference.

Budget 2024: TPO can evaluate SDTs not reported by taxpayers

July 26, 2024 1104 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 852 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 1971 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 5079 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 714 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 1536 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 1230 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 1644 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.

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