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 : The Tribunal held that the Indian entity was only a distributor and not a technology or content owner. It rejected the Revenue’s...
Income Tax : This explains the new block assessment mechanism allowing ALP to apply across multiple years. It emphasizes reduced disputes and s...
Income Tax : The issue concerns replacement of Form 3CEB with a new reporting framework. The reform mandates structured reporting with enhanced...
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 : The issue was whether high-turnover companies can be compared with a smaller software service provider. The Tribunal held that com...
Income Tax : The Tribunal held that transfer pricing adjustment cannot survive without a final assessment order post-DRP directions. Repeating ...
Income Tax : The Tribunal held that subscription to preference shares cannot be re-characterized as loans in absence of evidence showing sham t...
Income Tax : The tribunal held that the safe harbour limit applies to valuation determined by the DVO, not just stamp duty value. It ruled in f...
Income Tax : The Court held that Tribunal remand is not a fresh reference under transfer pricing law. Hence, limitation expired earlier, entitl...
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...
The court held that transfer pricing adjustments cannot automatically be treated as misreporting of income. Without evidence of deliberate concealment, penalty under Section 270A cannot be imposed.
Captive service providers operate with limited risk and must be benchmarked differently from entrepreneurial companies. The analysis explains why TNMM and cost-plus returns are the appropriate methods.
A detailed numerical illustration shows how the Cost Plus Method determines ALP for manufacturing transactions. The transfer price exceeded the permissible tolerance range, resulting in a transfer pricing adjustment.
The benchmark price was incorrectly determined because material economic differences between Thailand and Vietnam markets were not adjusted under the CUP method.
The Tribunal removed the transfer pricing addition on delayed receivables from associated enterprises, holding that the company’s profit margins exceeded comparable companies and interest was already embedded in pricing.
The Court quashed the TPO’s order after finding that copies of agreements relied upon were not supplied, holding that denial of such documents violated the taxpayer’s right to defend.
Indian tax authorities increasingly apply substance-over-form principles to offshore transactions, especially in source taxation and withholding obligations.
The government introduces unified safe harbours, faster APAs, and reduced litigation burdens to enhance certainty for multinational enterprises.
Reading The ‘Benefit’ Test Into Arm’s Length Price Determination: Throwing The Rulebook Out The Window 1. INTRODUCTION: Transfer Pricing Law, at its core, strikes at the distortion of ordinary business transactions, that occurs when related parties transact on terms inconsistent with competitive market conditions. Reportedly resorted to by Multinational Corporations in some instances, related-party transactions […]
ITAT held that the 10% tolerance band under property valuation provisions applies retrospectively. The PCIT’s revision was set aside as it amounted to a change of opinion.
