Income Tax : Explore the concept of transaction recharacterization in transfer pricing. Understand its rationale, benefits, and challenges in g...
Income Tax : Discover the key compliance dates for UAE transfer pricing regulations under the new corporate tax law effective from 1 June 2023....
Income Tax : India's Transfer Pricing regulations for FY 2023-24 (AY 2024-25) - This detailed chart lists key activities, legal sections, requi...
CA, CS, CMA : Learn about transfer pricing, its importance, methods, documentation, penalties for non-compliance, and advanced pricing agreement...
Income Tax : Understand the UAE's transfer pricing framework and benchmarks for managerial compensation under the new corporate tax law. Ensure...
Income Tax : From April 2025, TPOs can determine ALP for SDTs not initially referred or reported. This ensures accurate adjustments and complia...
Income Tax : What is the procedure to approve Form 3CEB? Form uploaded by CA shall be available under For your action tab in Taxpayer’s Workl...
Income Tax : ICAI Releases Exposure Draft Guidance Note On Report Under Section 92E Of Income-Tax Act, 1961 (Transfer Pricing) Based on the la...
Income Tax : Association for Corporate Advisers and Executives (ACAE) made a Request for Extension of Due Dates for filing Tax Audit and Transf...
Income Tax : Voice Of CA has made a Request for Extension of specified date of filing Tax Audit Report and other forms falling due on or before...
Income Tax : ITAT Hyderabad directed to exclude companies having turnover of more than or less than 10 times of the turnover of the assessee fr...
Income Tax : ITAT Mumbai held that no transfer pricing adjustment could have been made in the hands of assessee on account of ALP of specified ...
Income Tax : Learn how ITAT Bangalore ruled in favor of Herbalife India on technical service payments, clarifying FTS under India-USA DTAA. Det...
Income Tax : Explore the ITAT Hyderabad's decision on interest as an international transaction in Clinasia Labs Pvt Ltd vs ITO case. Detailed a...
Income Tax : ITAT Delhi rules RPM as the best method for benchmarking solar goods purchases in the D Light Energy P. Ltd. vs Assessing Officer ...
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...
Income Tax : Notification No. 46/2023-Income-Tax Dated: 26th June, 2023 regarding deemed arm's length price for assessment year 2023-2024. Le...
Income Tax : In exercise of the powers conferred by the third proviso to sub-section (2) of section 92C of the Income-tax Act, 1961 (43 of 1961...
Income Tax : Safe Harbour rules for AY 2022 2023 | Income tax Act, 1961 | Notification No. 66/2022-Income-Tax | Dated: 17th June, 2022 | CBDT...
ITAT has taken the view that it is open to the parties in Transfer Pricing cases to take a stand contrary to their TP study, if they contend that the stand taken in the TP study is contrary to facts or was erroneous. Such a claim cannot be disregarded only on the basis that it is contrary to Assessee’s own stand in the TP study.
ACIT Vs e4e Business Solutions India Pvt. Ltd. (ITAT Bangalore) TPO should choose the internal comparable in controlled transaction as against an external comparable The underlying object behind computing ALP of an international transaction is to find out the profits which such enterprise would have earned if the transaction had been with some third party […]
Bilakhia Holdings Pvt. Ltd. Vs ACIT (ITAT Surat) Facts- The Assessee Company being an investment company had received shares from its Promoters as a gift. The AO dismissed this claim stating that it was purchased by the assessee company at a discount from the said Promoters and that consideration was involved. Hence, AO disallowed the […]
Overview of Transfer Pricing Objective: – To understand the basic concept of Transfer pricing, Transfer Pricing Audit and adjustment along with key term used in Transfer Pricing. Transfer Pricing as describe in common parlance, where one business entity does business with other associate business entity. The sheer objective of Transfer Pricing Audit is to control […]
Lite-on Mobile India Pvt. Ltd. Vs DCIT (ITAT Chennai) Facts- TPO in respect of procurement of management services determined NIL arm’s length price by holding that the assessee didn’t bring any evidence on record to suggest that it was in need for services for which it has paid to its AEs. Further, assessee has availed […]
In India, though the Income Tax Act contained the concept of Transfer Pricing in Income Tax Act, 1922 itself, Globalisation & Liberalisation in the year of 1991, have led to the drastic increase in cross-border transactions thereby the need for sharing country’s revenue in a conscious and justified fair manner. Before going to TP documentation, […]
Transfer pricing provisions was incorporated in the Income Tax Act in April 2001 and now it has travel the journey of almost two decades in India. If we give one line principal to the transfer pricing provisions then it is benchmarking of international transactions entered with associated enterprises with comparables transactions (internal or external comparables) […]
Central Government Notifies Tolerance Band for Assessment Year 2021-22 in case of wholesale trading and others vide Notification No. 124/2021- Income Tax Dated: 29th October, 2021. MINISTRY OF FINANCE (Department of Revenue) Notification No. 124/2021- Income Tax New Delhi, the 29th October, 2021 S.O. 4586(E).—In exercise of the powers conferred by the third proviso to […]
Firemenich Aromatics Production (India) Pvt. Ltd. Vs ACIT (ITAT Mumbai) We find that IS charges were paid by the assessee for obtaining access to ERP software and for regular recurrent services and such charges were paid in earlier years also. In AY 2012-13, similar adjustment proposed by Ld. TPO was deleted by coordinate bench on […]
OECD published a report on the issue of ‘Base Erosion & Profit Shifting’, in which they set out 15 BEPS action plans to tackle the issue of base erosion and profit shifting. Since then OECD and G20 have continued to work on BEPS action through inclusive framework.
