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Transfer Pricing

Latest Articles


Assurance at Stake: Difficulties of PPT in light of BEPS Action 6 and MLI

Income Tax : Explore the Principal Purpose Test (PPT) in international tax law, its impact on treaty benefits, legal uncertainty, and potential...

March 26, 2025 171 Views 0 comment Print

Future of International Taxation: OECD Global Minimum Tax

Income Tax : Learn about income tax exemptions for universities, hospitals, and educational institutions under Section 10 of the Income Tax Act...

March 11, 2025 540 Views 0 comment Print

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 1347 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 945 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 636 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 1077 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 525 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 13671 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Draft Guidance Note on Transfer Pricing Report – Section 92E

Income Tax : ICAI Releases Exposure Draft Guidance Note On Report Under Section 92E Of Income-Tax Act, 1961 (Transfer Pricing) Based on the la...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 26163 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 11817 Views 1 comment Print


Latest Judiciary


Resale Price Method most appropriate as assessee acts as distributor and makes no value addition

Income Tax : Delhi High Court held that Resale Price Method (RPM) is the most appropriate method to determine arm’s length price since assess...

April 2, 2025 168 Views 0 comment Print

Existence of International Transaction Must Be Analyzed Before Benchmarking AMP Expense

Income Tax : Delhi High Court held that before undertaking a benchmarking of Advertisement, Marketing and Promotion [AMP expenses], it was incu...

March 31, 2025 75 Views 0 comment Print

Cost Allocation and Transfer Pricing – ITAT Bangalore Ruling

Income Tax : Advocate Amardeep Soni & Advocate Harsha Soni Gemplus India Pvt. Ltd. Vs ACIT (ITAT Bangalore) A Case Study of ITAT BANGALORE...

March 19, 2025 357 Views 0 comment Print

Fresh Adjudication Ordered on TPO Adjustment in Subsidiary Transaction

Income Tax : Bangalore ITAT overturns AO's PE classification of QlikTech India, orders fresh review based on TPO order, addresses TDS and inter...

March 9, 2025 84 Views 0 comment Print

Indian Subsidiary Not a Dependent Agency PE if Transactions Are Subject to TPO Adjustment

Income Tax : ITAT Bangalore sets aside AO's decision in Qlik Tech International AB vs DCIT, addressing PE classification, TDS credit, and tax r...

March 8, 2025 186 Views 0 comment Print


Latest Notifications


Amendment of Safe Harbour Rules for AY 2025-26 under Section 92CB

Income Tax : CBDT notifies Income Tax (Sixth Amendment) Rules, 2025, introducing safe harbour rules for assessment year 2025-26. Full details o...

March 25, 2025 876 Views 0 comment Print

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 1461 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 3744 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 11985 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 1749 Views 0 comment Print


Internal TNMM preferred over external TNMM considering a higher degree of comparability

January 15, 2022 2829 Views 0 comment Print

Neilsoft Private Limited Vs DCIT (ITAT Pune) This appeal by the assessee is directed against the final assessment order dated 13-04-2021 passed by the Assessing Officer u/s 143(3) r.w.s. 144C(13) r.w.s. 143(3A) & 143(3B) of the Income-tax Act, 1961 (hereinafter referred to as ‘the Act’) in relation to the assessment year 2016-17. 2. The only […]

ITAT allows Rental Income from subleasing of commercial properties for more than 12 Years as House Property Income

January 14, 2022 1824 Views 0 comment Print

DCIT Vs Pfizer Ltd (ITAT Mumbai) AO treated the rental income of Rs. 5,47,89,000/- received by the assessee from subleasing of commercial properties as income from business as against claim of the assessee being income from house property on the ground that renting out of premises amounts to commercial exploitation for business purpose by the […]

TP: Passing of final order without giving a Draft Assessment Order is bad in law

January 14, 2022 3867 Views 0 comment Print

Assessing Officer has assumed jurisdiction to straight away pass the final order without following the mandatory procedure prescribed under Section 144C of the Act. It is held in SHL (India) Private Limited (supra) that this is not a mere irregularity but an incurable irregularity.

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

January 12, 2022 6462 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 113127 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 3114 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 11817 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 28017 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 8682 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! […]

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