Income Tax : Explore the Principal Purpose Test (PPT) in international tax law, its impact on treaty benefits, legal uncertainty, and potential...
Income Tax : Learn about income tax exemptions for universities, hospitals, and educational institutions under Section 10 of the Income Tax Act...
Income Tax : Learn about the amendments to Section 92CA concerning references to the Transfer Pricing Officer for determining arm's length pric...
Income Tax : New transfer pricing rules allow arm’s length price (ALP) determinations to apply for two consecutive years, reducing compliance...
Income Tax : Finance Bill 2025 allows multi-year Arm’s Length Price determination for similar transactions, reducing repetitive proceedings i...
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 : 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Income Tax : ICAI Releases Exposure Draft Guidance Note On Report Under Section 92E Of Income-Tax Act, 1961 (Transfer Pricing) Based on the la...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 : Advocate Amardeep Soni & Advocate Harsha Soni Gemplus India Pvt. Ltd. Vs ACIT (ITAT Bangalore) A Case Study of ITAT BANGALORE...
Income Tax : Bangalore ITAT overturns AO's PE classification of QlikTech India, orders fresh review based on TPO order, addresses TDS and inter...
Income Tax : ITAT Bangalore sets aside AO's decision in Qlik Tech International AB vs DCIT, addressing PE classification, TDS credit, and tax r...
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...
Income Tax : ITAT Bangalore deletes AO’s protective addition in LM Wind Power case, citing settled MAP proceedings on IT fees and commission ...
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...
Income Tax : Notification No. 46/2023-Income-Tax Dated: 26th June, 2023 regarding deemed arm's length price for assessment year 2023-2024. Le...
Dabur India Ltd. Vs ACIT (ITAT Delhi) We have heard both the parties and perused the relevant material available on record. As regards to agreement with Dabur Nepal Pvt. Ltd. Nepal, it is pertinent to note that the issue stands covered in favour of the assessee by the order of the Tribunal in the asssessee’s […]
Synopsis of the Representation by ‘Bhayandar CA Social Group’ made for extension of due dates – To the Finance Ministry on 24-12-2021 We have not asked any extension of the due dates. We have asked for our fundamental right to be professionally engaged in the profession of the Chartered Accountancy by having seamless access to […]
AIMTPA has made a request to FM for Extension of Due Dates under Direct Tax of all the Forms and Returns (Including Income Tax Returns, Tax Audit and Transfer Pricing Audit Report) till 31st March 2022 without any penal condition in view of unavailability of the I.T. Portal, various glitches and frequently changing schemas taking […]
An associate enterprise itself would not to be taken as a comparable since lacking the independent nature of an uncontrolled transaction in forming hallmark of Chapter X of the Act. We thus delete the impugned arms length price adjustment on receivables for this precise reason alone.
Since the issue of benchmarking the international transaction is required to be examined qua both the segments i.e. CSDS and ITES separately and independently for factual analysis of taxpayer’s TP study, the case is remanded back to ld. TPO who shall determine the ALP of international transactions of both the segments independently afresh after providing an opportunity of being heard to the parties.
PCIT Vs Mount Kellett Capital Management India Pvt. Ltd. (Bombay High Court) Entire exercise of making transfer pricing adjustments on the basis of comparables is nothing but a matter of estimate of a broad and fair guess-work of the authorities based on factual relevant materials brought before the authorities, i.e., the TPO or Dispute Resolution […]
Cisco Systems Capital (India) Private Limited Vs DCIT (ITAT Bangalore) The assessee grievance is bundled approach for benchmarking should be accepted. At the outset, the ld. AR submitted that the TPO has accepted the bundled approach of aggregation of payment of fees for administrative support services in the preceding years (i.e. from the incorporation year […]
The TPO and DRP erred in treating CCDs as ECBs and benchmarked the interest rate against LIBOR rate. The CCDs is a hybrid instrument and cannot be per se treated as ECB / loan.
The Hon’ble ITAT deleted the transfer pricing adjustment on account of interest on receivables due to failure of revenue authorities to find out even a single comparable in assessee’s segment charging interest in uncontrolled market conditions.
It has held that difference in the level of capacity utilization is an accepted principle, though denied in the relevant AY to the respondent. The same cannot, however, tantamount to filing without good faith and due diligence.
