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Transfer Pricing

Latest Articles


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 516 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 1185 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 789 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 600 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 1251 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 1020 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 516 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 13623 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Draft Guidance Note on Transfer Pricing Report – Section 92E

Income Tax : ICAI Releases Exposure Draft Guidance Note On Report Under Section 92E Of Income-Tax Act, 1961 (Transfer Pricing) Based on the la...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 26145 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 11808 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 276 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 75 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 150 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


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 1377 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 3723 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 11946 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

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 2643 Views 0 comment Print


Delhi HC Upholds RPM for ALP in Burberry India Case

January 8, 2025 1455 Views 0 comment Print

Delhi High Court rules RPM as the best method for ALP in Burberry India transactions. Rejects Revenue’s AMP-based objections, providing clarity on transfer pricing.

Omission of Section 92BA(1) from 1/4/2017 Deems it Nonexistent from Insertion Date

January 7, 2025 399 Views 0 comment Print

Karnataka HC decision on transfer pricing adjustments and Section 92BA amendments in the PCIT vs TT Steel Service India Pvt. Ltd. case.

Transfer Price of Goods Sold via AE Allowed Based on ‘Other Method’ Instead of CUP

December 20, 2024 237 Views 0 comment Print

ITAT Mumbai allows Transfer Pricing determination for Rallis India Ltd. using the ‘Other Method’ instead of CUP. Key points on ALP adjustments and deductions.

Draft Assessment Orders in Transfer Pricing Cases: Legal Obligations under Section 144C

December 13, 2024 1905 Views 0 comment Print

Section 144C of IT Act, 1961 was brought through Finance Act, 2009 & introduced for orderly assessment with respect to the international tax case along with transfer pricing. Under this after serving a notice under it a draft assessment order would be given under which recipient shall receive chance of representation during dispute redressal for assessment before such assessment being made final.

Comparability Analysis must Focus on Functional Similarity Over Product Matching: Delhi HC

December 5, 2024 330 Views 0 comment Print

Delhi High Court upheld the ITAT’s decision, concluding that the comparability analysis must focus on functional similarity rather than strict product comparability, and that certain disallowances made by the Assessing Officer were unjustified.

Transfer Pricing Adjustments: Under-Reporting & Misreporting

November 24, 2024 4203 Views 0 comment Print

Understand penalties for under-reporting and misreporting of income in transfer pricing adjustments, as per the Income Tax Act 1961.

Chapter X of Income tax Act not applicable to non-AE transactions

November 4, 2024 1428 Views 0 comment Print

Chapter X of the Income Tax Act applies solely to transactions with Associated Enterprises (AEs), excluding non-AE transactions from transfer pricing provisions.

Comparable Selection for Arm’s Length Price Relies on Functional Similarity

November 3, 2024 471 Views 0 comment Print

Delhi High Court remands Alcatel Lucent’s transfer pricing case to ITAT, questioning selection of comparables in ALP determination. Detailed review of objections awaited.

High Brand Value, Large-Scale Operations & Lack of Segmented Data are valid Ground for Exclusion in ALP Determination

November 1, 2024 237 Views 0 comment Print

Delhi High Court judgment on Cadence Design’s appeal against the ITAT order regarding transfer pricing comparables. Key findings on ALP determination and comparability.

TP Adjustment of ₹166.09 Crore for Non-UK Royalties payment Remanded back to TPO

October 31, 2024 138 Views 0 comment Print

ITAT Delhi remands JCB India Ltd.’s ₹166.09 crore TP adjustment for non-UK royalty payments to TPO for fresh consideration.

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