Income Tax : This article explains how Safe Harbour Rules under the Income-tax Act, 2025 interact with APAs, MAP provisions, and transfer prici...
Income Tax : The framework outlines mandatory disclosures and timelines for opting into safe harbour. Key takeaway: strict compliance is essent...
Income Tax : The article explains how safe harbour rules simplify transfer pricing compliance. It highlights that eligible transactions are acc...
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 : 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 : ITAT Mumbai deleted the transfer pricing adjustment on management fees after finding that identical issues in the assessee’s own...
Income Tax : The ITAT held that transfer pricing adjustment was not justified where the foreign LLC’s income was already offered to tax in In...
Income Tax : ITAT Ahmedabad held that transfer pricing authorities cannot assign a NIL arm’s length price when the assessee has demonstrated ...
Income Tax : The Hyderabad ITAT found contradictions in the TPO’s reasoning for excluding a comparable company due to alleged lack of RPT dat...
Income Tax : Pune ITAT held that once TNMM is accepted for a taxpayer’s aggregated international transactions, the TPO cannot isolate a singl...
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 Bangalore held that as professional and consultation charges & purchase of fixed assets are capitalized in the books of accounts, it should not be considered for computation of proportionate TP adjustment.
Unlock the complexities of Transfer Pricing Rules for finance professionals. Dive into arm’s length pricing, methods, and compliance strategies. Stay informed to navigate the globalized business landscape.
Explore the intricacies of Transfer Pricing on Intra-Group Guarantees in India. This detailed discussion covers the meaning, determination of Arm’s Length Price, popular methods, and ongoing debates. Stay informed to navigate Transfer Pricing regulations effectively.
ITAT Mumbai held that when the transaction is in the reimbursement of expenses to AE, the third party cost incurred is a Comparable Uncontrolled Price (CUP) for the reimbursement. Accordingly, adjustment proposed is directed to be deleted.
Tribunal Decision determining ALP can be challenged on grounds of perversity & non observance of transfer pricing rules in individual cases
SAP Labs India Private Vs ITO (Supreme Court of India) Whether in every case where the Tribunal determines the arm’s length price, the same shall attain finality and the High Court is precluded from considering the determination of the arm’s length price determined by the Tribunal, in exercise of powers under Section 260A of the […]
ITAT Delhi held that deriving Arm’s Length Price without resorting to any method prescribed as per the Income Tax Rules is unjustifiable. Accordingly, TPO/ AO directed to determine Arm’s Length Price.
ITAT Delhi held that when the transaction between the assessee and its Indian AE is found to be at arm’s length, no further attribution of profit can be made to the dependent agent PE in India.
Calcutta High Court held that mere usage of foreign word does not make it automatic to fall within the ambit of an international transaction.
Philips India Ltd. vs ACIT (ITAT Kolkata) In many cases, licensed manufacturers operate as risk-bearing entrepreneurs, and there is no existence of an ‘agreement’ or ‘arrangement’ or ‘understanding’ with the AE regarding AMP expenditure, the initial onus is on the revenue to show that there is an international transaction for AMP spend. The mere fact […]
