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Transfer Pricing

Latest Articles


Budget 2025: Transfer Pricing Amendments

Income Tax : Learn about the amendments to Section 92CA concerning references to the Transfer Pricing Officer for determining arm's length pric...

February 4, 2025 921 Views 0 comment Print

Transfer Pricing Amendments: Multi-Year ALP Determination

Income Tax : New transfer pricing rules allow arm’s length price (ALP) determinations to apply for two consecutive years, reducing compliance...

February 3, 2025 651 Views 0 comment Print

Transfer Pricing: Multi-Year ALP Determination in Budget 2025 – FAQs

Income Tax : Finance Bill 2025 allows multi-year Arm’s Length Price determination for similar transactions, reducing repetitive proceedings i...

February 2, 2025 531 Views 0 comment Print

Finance Bill 2025: Amendment related to Transfer Pricing

Finance : The Finance Bill 2025 proposes multi-year ALP determination to reduce compliance burdens in transfer pricing. Learn about its fram...

February 1, 2025 1002 Views 0 comment Print

Section 92BA(i) Prevision Treated as Never Existed: Karnataka HC

Income Tax : Karnataka HC ruled that omission of Section 92BA(i) invalidates its application to domestic transactions, limiting transfer pricin...

January 24, 2025 348 Views 0 comment Print


Latest News


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 942 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 465 Views 0 comment Print

FAQ’s on filing of Income Tax Form 3CEB

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...

October 28, 2022 13554 Views 0 comment Print

Draft Guidance Note on Transfer Pricing Report – Section 92E

Income Tax : ICAI Releases Exposure Draft Guidance Note On Report Under Section 92E Of Income-Tax Act, 1961 (Transfer Pricing) Based on the la...

July 21, 2022 26124 Views 1 comment Print

ACAE Requested due date extension for filing Tax & TP Audit

Income Tax : Association for Corporate Advisers and Executives (ACAE) made a Request for Extension of Due Dates for filing Tax Audit and Transf...

January 7, 2022 11787 Views 1 comment Print


Latest Judiciary


Relief to Bloomsbury Publishing in Transfer Pricing Case

Income Tax : It was held that transactions and FAR of assessee were similar to AY 2021-­22 and as per the records brought to our notice, there...

February 17, 2025 66 Views 0 comment Print

Indian AE Transactions at Arm’s Length, HC Says No More Attribution

Income Tax : Respondent/assessee is a Irish company. It accordingly claimed benefits of the India-Ireland DTAA. ADIR is a wholly owned subsidia...

February 13, 2025 114 Views 0 comment Print

Taxpayer Must Provide Comparable Data in Foreign AE Cases:: ITAT remanded matter

Income Tax : In the matter above-mentioned ITAT partly allowed the appeal filed by the assessee by remanded it back to file of TPO after consid...

February 13, 2025 99 Views 0 comment Print

State Electricity Board Rates Determine Market Price of Power: Delhi HC

Corporate Law : Delhi HC rules that SEB rates, not IEX rates, determine the market price of electricity in transfer pricing cases, dismissing Reve...

January 29, 2025 447 Views 0 comment Print

Notional Income Winding-Up Costs Not Taxable in Transfer Pricing: ITAT Delhi

Income Tax : ITAT Delhi clarifies tax treatment for Motricity India: No levy on notional income or closure costs. Insights on Transfer Pricing ...

January 15, 2025 249 Views 0 comment Print


Latest Notifications


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 1212 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 3687 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 11871 Views 0 comment Print

Deemed Arm’s Length Price for Assessment Year 2023-2024

Income Tax : Notification No. 46/2023-Income-Tax Dated: 26th June, 2023  regarding deemed arm's length price for assessment year 2023-2024. Le...

June 26, 2023 1722 Views 0 comment Print

Tolerance Band for AY 2022-23 in case of wholesale trading & others

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...

June 28, 2022 2628 Views 0 comment Print


Take practical view of problems faced by assessees for technical glitches on new Income Tax portal: HC

January 12, 2022 6378 Views 0 comment Print

We request the authority concerned to take a practical view of the problems which the assessees are facing as on date on account of the technical glitches in the portal. The authority should not overlook this fact and try to solve the problems or rather ease the difficulties which the assessees are facing.

Income Tax Audit Due & ITR Due date for AY 2021-22 extended

January 11, 2022 111720 Views 1 comment Print

On consideration of difficulties reported by taxpayers/stakeholders due to Covid & in e-filing of Audit reports for AY 2021-22 under the IT Act, 1961, CBDT further extends due dates for filing of Audit reports & ITRs for AY 21-22. Income Tax Audit date extended to 15 Feb 2022 and Income Tax Return date extended to […]

RPM method used by Taxpayer cannot be rejected without pointing defect in the same

January 11, 2022 3078 Views 0 comment Print

Randox Laboratories India Private Limited Vs ACIT (ITAT Bangalore)  The facts on record reveal that the Transfer Pricing Officer under a misconception that the assessee has undertaken manufacturing activity has rejected RPM. Learned DRP has also not examined the facts in proper perspective. Rather, learned DRP has recorded an erroneous finding by stating that in […]

ACAE Requested due date extension for filing Tax & TP Audit

January 7, 2022 11787 Views 1 comment Print

Association for Corporate Advisers and Executives (ACAE) made a Request for Extension of Due Dates for filing Tax Audit and Transfer Pricing (TP) Reports to as follows:- 1) The due date of furnishing of Report of Audit under any provisions of the Act, which was 30 September 2021, and extended to 15 January 2022 is […]

Request to extend due dates of Tax Audit Report & Other forms

January 7, 2022 28005 Views 12 comments Print

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 15th January, 2022 to Smt Nirmala Sitaraman Ji, Hon’ble Minister of Finance, Government of India. Voice Of CA <voiceofca@gmail.com> Wed, Jan 5, 2022 at 12:52 PM To: fmo@nic.in | Cc: […]

Request to Extend Due Dates for filing Tax & Transfer Pricing Audit

January 7, 2022 8667 Views 1 comment Print

Chamber of Tax Consultants has made a Request for Extension of Due Dates for filing Tax Audit and Transfer Pricing Reports to Smt. Nirmala Sitharaman, Hon’ble Finance Minister,Ministry of Finance. Full text of their representation is as follows:- The Chamber of Tax Consultants Date: 7th January, 2022 To, 1. Smt. Nirmala Sitharaman, Hon’ble Finance Minister, […]

Request to extend due date of Tax Other Audit Reports

January 7, 2022 5148 Views 0 comment Print

Tax Bar Association, Jodhpur has made a Request for extension of due date of Tax Audit Report and Other Reports for a month. Relevant Text of their representation is as follows:- TAX BAR ASSOCIATION JODHPUR (Rajasthan) Date: 07th January, 2022 To, Hon’ble Finance Minister. Ministry of Finance New Delhi Hon’ble Madam, Greetings of the Day! […]

ICAI request waiver of Penalty for delay in filing Income Tax Audit Reports

January 6, 2022 11343 Views 1 comment Print

ICAI, Indore has requested CBDT Chairman to consider waiver of penalty for delay in furnishing of Report of Audit under any provision of the Income-tax Act, 1961 for the A. Y. 2021-22. Full Text of their representation is as follows:- THE INSTITUTE OF CHARTERED ACCOUNTANTS OF INDIA (Set up by an Act of parliament) Indore (CIRC) Indore/2021-22/Rep-1 […]

TPO erred in holding ALP at nil on the ground that relevant documents not been submitted

January 5, 2022 1392 Views 0 comment Print

PPG Coatings India Pvt. Ltd. Vs DCIT (ITAT Mumbai) It was submitted that SAP license was purchased by the AE at Netherland in bulk quantities. A copy of the agreement entered into between the said AE and the third party along with the copy of the debit note raised by the AE was submitted. It […]

Performance incentive not paid before due date of return not allowable

January 5, 2022 14412 Views 0 comment Print

Hyundai Motor India Ltd. Vs ACIT (ITAT Chennai) The next issue that came up for consideration from ground No. 6 of assessee appeal is disallowance u/s.43B(c) of the Act, in respect of performance incentive paid to employees. Facts with regard to impugned dispute are that for the financial year relevant to the assessment year 2016-17, […]

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