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...
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.
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.
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.
Learn from PCIT Vs Radhashir Jewellery Co. Pvt Ltd. case why comparing new and established businesses in transfer pricing is inappropriate. Detailed analysis provided.
Discover the intricacies of structuring cross-border mergers and acquisitions (M&A). Learn about key steps, due diligence, legal compliance, and tax considerations for successful transactions.
Country-by-Country Reporting (CbCR) is a crucial component of the transfer pricing documentation requirements introduced by the Organization for Economic Co-operation and Development (OECD) as part of the Base Erosion and Profit Shifting (BEPS) Action Plan.
Learn about Transfer Pricing compliance and assessment procedures, including ALP determination, TPO reference, DRP mechanism, APAs, and penalties for non-compliance.
Explore the significance of transfer pricing in international taxation and corporate finance. Learn about arm’s length pricing, methods for computation, and the impact of secondary adjustments.
Analysis of Maharashtra Seamless Ltd Vs DCIT case where no transfer pricing adjustment was needed as the assessee earns interest at arm’s length rate.
Delhi High Court rules in favor of Oriflame India Pvt Ltd, withdrawing TPO’s proposed income adjustments, applies TNMM over RPM. Details of the case analysis here.
