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...
ITAT Mumbai held that Arm’s Length Price (ALP) of guarantee commission was determined at the rate of 0.3523% instead of 1.25%.
ITAT Mumbai held that once only comparable as chosen by DRP fails, then same loses the comparability for determining the ALP.
Delhi High Court supports ITAT’s verdict on the selection of comparables for determining the Arm’s Length Price of an international transaction. Get insights on PCIT vs Chrys Capital
Delhi High Court upholds ITAT’s decision: Advertising, Marketing, and Promotion (AMP) expenses by Wrigley India Pvt. Ltd. not considered an international transaction.
In a landmark ruling, the Delhi High Court held that government shareholders are not automatically considered related parties under Section 92E of the Income Tax Act, 1961. This decision has significant implications for companies with government shareholding.
ITAT that as long as the charges for hourly services provided by appellant were uniform to AEs and third parties, rejection of CUP method was unwarranted.
The Delhi High Court directs the ITAT to reconsider the exclusion of Onward Technologies Limited (OTL) as a comparable in the transfer pricing study. Detailed analysis and conclusion.
Delhi High Court upheld the exclusion of comparables due to functional dissimilarity and significant turnover differences. Analysis of the PCIT vs. Qualcomm India Pvt Ltd case.
The Income Tax Appellate Tribunal (ITAT) in Pune deleted the penalty in the Jyoti Paper Udyog Ltd Vs. ACIT case due to non-production of Form No. 3CEB under Section 92E.
Explore landmark cases like SAP Labs vs. IT Officer, Evalueserve vs. Commissioner, and Softbrands vs. IT. Learn how the law and facts intersect in transfer pricing disputes.
