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...
ITAT Mumbai held that as TPO has gathered financial and functional details of the company by way of using his authority under section 133(6) of the Income Tax Act hence the same needs to provide all the gathered information to the assessee.
Learn about the special features of Advance Pricing Agreements (APAs) in India, annual compliances, revision, cancellation, and more in this detailed guide
What is the procedure to approve Form 3CEB? Form uploaded by CA shall be available under For your action tab in Taxpayer’s Worklist. Taxpayer may either approve or reject form 3CEB.
The transfer pricing rules are meant to prevent tax leakage and market distortion that may result from the prices set for transactions among related parties. While cost-plus is one of the most commonly used methods to assign an appropriate price for a product or service, it’s not the best method to follow in all cases.
PCIT Vs Amway India Enterprises (Delhi High Court) In the present appeal, the learned counsel for the Appellant states that the ITAT erred in confirming the order of the CIT(A) and failed to appreciate the fact that the royalty payment is excessive and not at arm’s length on consideration of Advertisement, Marketing and Promotion (‘AMP’) […]
Court is of the view that every Assessment Year is a separate unit which is governed by its own peculiar facts and difference of opinion between the parties, as to the appropriateness of one or the other methods to calculate arm’s length price, cannot per se be a ground for interference
Dive into the evolution of taxation for MNEs with Pillar 2 – Global Minimum Tax. Understand the mechanics, implications, and exceptions of this groundbreaking framework to stay informed in the changing landscape of global taxation.
ITAT Bangalore held that in the absence of no written agreement exists between the assessee and its AE requiring the assessee to incur advertisement, marketing and promotion (AMP) expenses, the same cannot be regarded as an international transaction at all and hence TP adjustment not sustainable
Explore the critical analysis of the ITAT Delhi order in the Karcher India Pvt. Ltd. case regarding the applicability of the Resale Price Method (RPM) for a distributor’s international transactions. Understand the legal nuances and implications.
DCIT Vs Ferrero India Pvt. Ltd (ITAT Pune) The main contention that was advanced by the assessee in this case before the Tribunal was that the existence of international transaction cannot be inferred by the T.P.O in the absence of any actual transaction and the presumption by the lower authorities that the benefit had endured […]
