Income Tax : Section 144C of IT Act, 1961 was brought through Finance Act, 2009 & introduced for orderly assessment with respect to the interna...
Income Tax : Understand penalties for under-reporting and misreporting of income in transfer pricing adjustments, as per the Income Tax Act 196...
Income Tax : Chapter X of the Income Tax Act applies solely to transactions with Associated Enterprises (AEs), excluding non-AE transactions fr...
Income Tax : Revenue authorities lack jurisdiction to question the business decisions or commercial wisdom of taxpayers in transfer pricing cas...
Income Tax : The ITAT remands BorgWarner's case on TSS, BSS, and royalty benchmarking to TPO for re-determination, questioning the segregation ...
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Income Tax : ICAI Releases Exposure Draft Guidance Note On Report Under Section 92E Of Income-Tax Act, 1961 (Transfer Pricing) Based on the la...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 : Delhi High Court upheld the ITAT’s decision, concluding that the comparability analysis must focus on functional similarity rath...
Income Tax : Delhi High Court remands Alcatel Lucent's transfer pricing case to ITAT, questioning selection of comparables in ALP determination...
Income Tax : Delhi High Court judgment on Cadence Design's appeal against the ITAT order regarding transfer pricing comparables. Key findings o...
Income Tax : ITAT Delhi remands JCB India Ltd.'s ₹166.09 crore TP adjustment for non-UK royalty payments to TPO for fresh consideration....
Income Tax : Delhi HC ruling clarifies that KPO service providers aren't comparable to ITES providers for benchmarking international transactio...
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...
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...
Internal Comparable Uncontrolled Price Method (CUP) to be preferred as the Most Appropriate Method over External CUP, where direct internal comparable price is available.
Evolving Systems Networks India Pvt. Ltd. Vs DCIT (ITAT Bangalore) The only other ground pressed was with regard to the action of the TPO in treating provision for bad and doubtful debts as part of non operating expense while computing operating margin of comparables. Karnataka High Court has also taken a view in the case […]
Transfer pricing refer to the strategies which determine the trading price for goods or services between the related parties which is defined under Section 2(76) of Companies act 2016 and covered in AS 18 and IND AS 24. Transfer pricing empowers changes in pricing. Transactions under Transfer pricing between related entities in different countries is one of the most important and complex issue of taxation which global companies face.
Wieland Metals India Private Ltd. Vs ITO (ITAT bangalore) Issue before us is with regard to TP adjustment by applying TNMM by the TPO instead of CUP method adopted by the assessee as most appropriate method in respect of determining of ALP of manufacturing segment. As seen from the details of international transactions, the assessee […]
Increase in brand value due to use of foreign AEs brand name in Taxpayer’s products cannot be considered as provision of services, as per international transaction definition u/s 92B of the Income Tax Act, 1961.
Bennett Coleman & Co Ltd Vs DCIT (ITAT Mumbai) What is being termed as a guarantee is the obligation of the assessee company, in terms of “agreement for the sale and purchase of entire equity share capital of Virgin Radion Holdings Ltd UK” dated 30thMay 2008, which has led to the actual crystallization of sale […]
The Finance Ministry vide Circular no. 17/2021 dated 09 September, 2021 announced extensions to the deadline for the filing of the Income-tax Returns, as well as some other allied compliances for the Assessment Year 2021-22: Sr. No. Particulars Original Due Date Extended to vide earlier Circular no.9/2021 Now Extended to vide Latest Circular no. 17/2021 […]
Conduct of the assessee in complying with 12 items out of 16 items as called for by the TPO can be considered to be reasonable and the act cannot be held to be an unreasonable act, but can be considered as a reasonable act of an organization acting with prudence under normal circumstances without negligence or inaction or want of bonafides.
An interest-free debt funding of an overseas company in the nature of a special purpose vehicle (SPV), with a corresponding obligation to use it for the purpose of acquisition of a target company abroad, could not be compared with a loan simpliciter, and be, subjected to an arm’s length price adjustment on account of notional interest on a loan by assessee company to its fully owned foreign subsidiary as balances reflected on account of exchange difference for notional conversions could not be treated as outstanding dues.
The related party transactions have always been under the close scanner of the Tax Authorities. Owing to the inherent nature of such transactions it is believed that such transactions are by far the most convenient way of shifting profits and accordingly subjected to detailed scrutiny by the Tax Authorities. The international transactions have been under […]
