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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 138 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 531 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 1227 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 855 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 615 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 1032 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 519 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 13647 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Draft Guidance Note on Transfer Pricing Report – Section 92E

Income Tax : ICAI Releases Exposure Draft Guidance Note On Report Under Section 92E Of Income-Tax Act, 1961 (Transfer Pricing) Based on the la...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 26148 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 11811 Views 1 comment Print


Latest Judiciary


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 333 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 78 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 162 Views 0 comment Print

Comparable cannot be excluded in Absence of Persistent Losses: ITAT Delhi

Income Tax : ITAT Delhi directs inclusion of Magma Advisory Services Ltd. in Honda R&D's comparable list, rejecting TPO's reasons and DR's func...

February 28, 2025 168 Views 0 comment Print

Protective Addition Unsustainable if Substantial Addition is Confirmed or Settled: ITAT Bangalore

Income Tax : ITAT Bangalore deletes AO’s protective addition in LM Wind Power case, citing settled MAP proceedings on IT fees and commission ...

February 27, 2025 198 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 26, 2025 438 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 1404 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 3729 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 11967 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 1737 Views 0 comment Print


Performance incentive not paid before due date of return not allowable

January 5, 2022 14520 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, […]

Memorandum for Extension of Due Date for filing of Income Tax Audit Report

January 5, 2022 23829 Views 4 comments Print

Direct Taxes Professionals’ Association (DTPA), Kolkata has made a representation for Extension of Due Date for filing of Income Tax Audit Report under Income Tax Act to Hon’ble Smt. Nirmala Sitharaman Ji, Union Minister of Finance, Ministry of Finance. Full Text of her representation is as follows:-  DIRECT TAXES PROFESSIONALS’ ASSOCIATION Income Tax Building, 3, […]

Request for Section 234F Late Fees waiver & extension of TAR/ITR due dates

January 5, 2022 22668 Views 0 comment Print

Tax Advocates Association Gujarat has made a Request for waiver of Late Fees under section  234 F of the Income Tax Act, 196 and extension of DUe Date for filing of audit report & audited Income Tax Return for A.Y. 2021-22. Full Text of their representation is as follows:- Tax Advocates Association Gujarat To, 1. […]

Representation regarding Extension of Income Tax Due Dates

December 31, 2021 22416 Views 13 comments Print

District Taxation Bar Association (Direct Taxes), Ludhiana has made a representation to FM Smt. Nirmala Sitharaman Ji and  requested for extension of time for filing income tax returns in the light of the issues and problems being faced by the Members & the Assessees. District Taxation Bar Association (Direct Taxes), Ludhiana Dated: 27.12.2021 To Smt. […]

Glitches on Income Tax Portal & request for due date extension

December 28, 2021 15672 Views 2 comments Print

The Chamber Of Tax Consultants has made a representation to Smt. Nirmala Sitharaman on Technical glitches in the Income-tax e-fining portal and  Requested for Extension of due dates for filing Return of Income. Full text of their representation is as follows:- THE CHAMBER OF TAX CONSULTANTS Date: 27th December, 2021 To, 1. Smt. Nirmala Sitharaman, […]

Request to Extend due dates under Income Tax Act & Companies Act

December 28, 2021 27723 Views 1 comment Print

Delhi Tax Bar Association has made a representation to Hon’ble FM Nirmala Sitharaman Ji and requested for Extension of Due Dates for Submission of Income Tax Returns and various Audit Reports under the Income Tax Act and Companies Act. DELHI TAX BAR ASSOCIATION Formerly Bar Association (Income Tax) (ESTD. 1954-55) G-09, CENTRAL REVENUE BUILDING, INDRAPRASTHA […]

Request to extend due date for filing ITR & TARs | AY 2021-22

December 27, 2021 53142 Views 7 comments Print

All Odisha Tax Advocates Association has requested FM to consider the genuine difficulties of the assessees and Tax Professionals and be generous to pass an order to extend the due date of filing of the return of income of the assessees to 28/02/2022 in place of 31/12/2021 and the TARs from 15/01/2022 to 28/02/2022 and […]

Extend due dates of ITR & Tax audit report submission

December 26, 2021 26745 Views 4 comments Print

Chandigarh Chartered Accountants Taxation Association has made a representation to Finance Minister for Extension of due dates of Income tax returns & Submission of Tax audit reports for FY 2020-21 (AY 2021-22) in view of Practical difficulties faced by taxpayers & tax professionals in filing Income tax returns, tax audit form. Full Text of their […]

Bright-line test for TP adjustment on AMP expenditure is unsustainable in law

December 25, 2021 7161 Views 0 comment Print

Timex Group India Ltd. Vs ACIT (ITAT Delhi) Brief facts of the case are that the assessee is a company engaged in the business of manufacture, trading, sale and servicing of quartz, analogue and digital watches and watch components; manufacture and sale of plastic components, tools and moulds; and rendering information technology and financial support […]

ITeS’ functionally not comparable to Knowledge Process Outsourcing

December 25, 2021 2094 Views 0 comment Print

The assessee company provides back office support services to AEs with the help of tools, infrastructure and training provided by the AEs which is different than the functions of the KPO.

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