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...
Explore the Cost Plus Method for transfer pricing. Learn its application, methodology, and key considerations. Navigate complexities with practical examples.
Explore the intricacies of Resale Price Method (RPM) in transfer pricing. Understand its components, implementation steps, and real-world applications. Dive into case examples highlighting strengths, weaknesses, and considerations for reliable comparisons
This section delves into transactional profit methods, which serve to analyze the profits derived from specific controlled transactions to ascertain if the transfer price aligns with arm’s length principles. Within this category, two primary methods are discussed: the Transactional Net Margin Method (TNMM) and the Profit Split Method (PSM).
Explore the judgment in Bombardier Transportation India Pvt. Ltd. Vs DCIT by Delhi High Court. The court remits the matter for determining the Arm’s Length Price (ALP) method.
Explore the Comparable Uncontrolled Price (CUP) method in transfer pricing – its methodology, application, benefits, risks, case study, and insights on when to use. Learn more!
Explore the Thin Cap Adjustment Provisions under Section 94B of the Income Tax Act, addressing base erosion and profit shifting. Learn about its impact on NBFCs, start-ups, and global approaches.
Delhi HC upholds 15% attribution rate of revenue for Indian operations of Permanent Establishment based on gross booking by Travelport Global Distribution Systems B.V.
Delhi High Court upholds ITAT’s decision to exclude comparables Accentia, Eclerx, Mold-Tek, and TSR in the PCIT vs. Honeywell International transfer pricing case.
Explore detailed analysis of Hon’ble ITAT Pune decisions in 2023 on transfer pricing, covering allocation of expenses, custom duty, working capital, methods, and more.
Understand the intricacies of Transfer Pricing Audits in international transactions, mandated by Section 92E of the Income Tax Act, 1961. Learn how to ensure compliance, maintain accurate documentation, and avoid disputes, safeguarding your company’s global tax practices.
