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 : The Tribunal held that the Indian entity was only a distributor and not a technology or content owner. It rejected the Revenue’s...
Income Tax : This explains the new block assessment mechanism allowing ALP to apply across multiple years. It emphasizes reduced disputes and s...
Income Tax : The issue concerns replacement of Form 3CEB with a new reporting framework. The reform mandates structured reporting with enhanced...
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 : The issue was whether high-turnover companies can be compared with a smaller software service provider. The Tribunal held that com...
Income Tax : The Tribunal held that transfer pricing adjustment cannot survive without a final assessment order post-DRP directions. Repeating ...
Income Tax : The Tribunal held that subscription to preference shares cannot be re-characterized as loans in absence of evidence showing sham t...
Income Tax : The tribunal held that the safe harbour limit applies to valuation determined by the DVO, not just stamp duty value. It ruled in f...
Income Tax : The Court held that Tribunal remand is not a fresh reference under transfer pricing law. Hence, limitation expired earlier, entitl...
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...
Explore intricacies of Related Party Transactions under AS 18 and Transfer Pricing in India. Understand control, influence, disclosure requirements and how arm’s length principle is applied.
Delhi High Court grants relief to Travelport LP USA as it upholds CIT’s 15% revenue attribution to PE in India. Full text and analysis of the judgment.
Bombay HC clarifies bank guarantee vs. corporate guarantee distinctions in Everest Kento Cylinders case. Ruling impacts income tax computation.
Dive into BEPS 2.0 with an in-depth analysis of Pillar One & Pillar Two proposals, reshaping international tax. Explore the impact, India’s stance, and global implications.
Stay informed on the latest Income Tax Rule changes with Notification No. 104/2023 by the Ministry of Finance. Learn about amendments and their impact.
Explore Delhi High Court’s nuanced judgment in PCIT vs. Future First Info. Services Pvt. Ltd., emphasizing KPO exclusion in transfer pricing analysis.
Explore the rules and challenges of Domestic Transfer Pricing (DTP) in India. Learn about legal definitions, threshold limits, applicability, Arm’s Length Price, documentation, issues, and techniques.
ITAT Mumbai held that the rates on which power is available through Indian Energy Exchange cannot be applied, because these are not the rates to the consumers but rates to the DISCOMs. Accordingly, transfer pricing adjustment deleted.
Explore Delhi HC judgment in PCIT vs. Fujitsu India Ltd. for AY 2011-14, focusing on Transfer Pricing Method. Analysis of TNMM vs. RPM with key findings. Insights and conclusion provided.
Delhi HC ruled on appeal in PCIT vs Global Logic India Ltd, upholding exclusion of comparables due to absence of segmental info & treatment of foreign exchange gain/loss as operating income/operating loss
