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Transfer Pricing

Latest Articles


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 942 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 666 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 552 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 1017 Views 0 comment Print

Section 92BA(i) Prevision Treated as Never Existed: Karnataka HC

Income Tax : Karnataka HC ruled that omission of Section 92BA(i) invalidates its application to domestic transactions, limiting transfer pricin...

January 24, 2025 351 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 951 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 465 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 13554 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Draft Guidance Note on Transfer Pricing Report – Section 92E

Income Tax : ICAI Releases Exposure Draft Guidance Note On Report Under Section 92E Of Income-Tax Act, 1961 (Transfer Pricing) Based on the la...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 26124 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 11787 Views 1 comment Print


Latest Judiciary


Relief to Bloomsbury Publishing in Transfer Pricing Case

Income Tax : It was held that transactions and FAR of assessee were similar to AY 2021-­22 and as per the records brought to our notice, there...

February 17, 2025 69 Views 0 comment Print

Indian AE Transactions at Arm’s Length, HC Says No More Attribution

Income Tax : Respondent/assessee is a Irish company. It accordingly claimed benefits of the India-Ireland DTAA. ADIR is a wholly owned subsidia...

February 13, 2025 117 Views 0 comment Print

Taxpayer Must Provide Comparable Data in Foreign AE Cases:: ITAT remanded matter

Income Tax : In the matter above-mentioned ITAT partly allowed the appeal filed by the assessee by remanded it back to file of TPO after consid...

February 13, 2025 102 Views 0 comment Print

State Electricity Board Rates Determine Market Price of Power: Delhi HC

Corporate Law : Delhi HC rules that SEB rates, not IEX rates, determine the market price of electricity in transfer pricing cases, dismissing Reve...

January 29, 2025 447 Views 0 comment Print

Notional Income Winding-Up Costs Not Taxable in Transfer Pricing: ITAT Delhi

Income Tax : ITAT Delhi clarifies tax treatment for Motricity India: No levy on notional income or closure costs. Insights on Transfer Pricing ...

January 15, 2025 249 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 1224 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 3687 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 11877 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 1722 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 2628 Views 0 comment Print


Extend due dates of GST, Income Tax & ROC Compliances

January 10, 2021 48798 Views 14 comments Print

All India Joint Representation Committee for GST have filed representation by way of join petition of 24 GST and Trade Associations and 5226 signatories to the signature campaign considering short extension granted in connection with GSTR 9 & 9C for FY 1819 & FY 1920 , Income Tax Returns, Tax Audit and Transfer Pricing Reports […]

Take appropriate decision on extension of due date of filing ITR & TAR by 12.01.2021: Gujarat HC to CBDT

January 10, 2021 4275 Views 2 comments Print

The Hon’ble High Court, Gujarat in the All Gujarat Federation of Tax Consultants v. Union of India [R/Special Civil Application No. 13653 of 2020 dated January 8, 2021] directed CBDT to take an appropriate decision for extension of the due date of filing income tax return (ITR) and Tax audit report (TAR) by January 12, […]

What if Due Date for filing ROI on 10th January 2021 falls on a Sunday?

January 10, 2021 29697 Views 1 comment Print

10th January 2021, the last date of filing of ROI u/s 139(1), falls on Sunday. In such a case what should be the due date ROI u/s 139(1)? 10th January 2021 or 11th January 2021? Opinions varies. An analysis of the provisions affecting the Due Date may perhaps clarify the issue. General Clauses Act 1977: […]

Extend due dates of TAR/ITRs/VSV Scheme for AY 2020-21

January 9, 2021 21339 Views 4 comments Print

Calcutta Citizens’ Initiative, Representation on Extension of due dates of Vivad Se Vishwas Scheme and also for extension of date for TAR and ITRs for asst year 2020-21. Calcutta Citizens’ Initiative 3, Ho Chi Minh Sarani, Ground Floor, Kolkata 700001 Ph – 033-2466-1000 Email: calcuttacitizens@gmail.com URGENT Ref. CII/Rep/2021/01 Dated: 9th January 2021 Shri P.C. Mody, Chairman, […]

Further extend Income Tax Return & Audit due dates

January 9, 2021 82977 Views 4 comments Print

Direct Taxes Professionals’ Association, Kolkata has requested FM for further extension of various due dates under Income-tax Act, 1961 especially Income Tax Return Forms for AY 2020­- 21, Tax Audit Reports and other related Returns for AY 2020­- 21. Text of their representation is as follows:- DIRECT TAXES PROFESSIONALS’ ASSOCIATION Income Tax Building, 3, Govt. […]

Consider extension of Income Tax Due dates: Gujarat HC to UOI

January 8, 2021 25599 Views 0 comment Print

All Gujarat Federation of Tax Consultants Vs Union of India (Gujarat High Court) High Court held that respondent No.1 – Union of India, Ministry of Finance should immediately look into the issue, more particularly, the representation dated 12th October 2020 at Annexure : I of the paper book (page 108) and take an appropriate decision […]

AIFTP request for further extension of Income-tax due dates

January 8, 2021 19002 Views 2 comments Print

AIFTP Representation for further extension of various due dates under Income-tax Act, 1961 especially Income Tax Return Forms for AY 2020­- 21, Tax Audit Reports and other related Returns for AY 2020­- 21

ICAI request for further extension of TAR/ITR due dates

January 8, 2021 58104 Views 14 comments Print

ICAI request FM to consider further extension(s) of various due dates under Income-tax Act, 1961 especially Tax Audit Reports (TAR) and related returns and Income Tax Return (ITR) Forms  for AY 2020-21. text of their representation is as follows:- ICAI/DTC/2020-21/Rep-31 To Chairman, Central Board of Direct Taxes, Ministry of Finance, Government of India, North Block, […]

CA Association Criticised Action & Policies of FMO after insufficient due date extension

January 8, 2021 46260 Views 11 comments Print

Chartered Accountants Association, Surat has written a letter to FM and criticized Finance Minister Office (FMO) for its Poor Actions and Policies. As per the letter Actions of FMO ultra-vires the Citizen’s Charter, Deteriorated working standards and health of the stakeholders, FMO failed in recognition of efforts put by the tax professionals, Ignoring communication with […]

Extend Income-tax due dates with humane approach

January 5, 2021 53160 Views 38 comments Print

The Chamber of Tax Consultants has made a representation TO FM & CBDT and requested for Extension of various due dates for compliances under the Income-tax Act, 1961 and also Requested FM & CBDT to adopt humane approach in handling the extension of due dates in the times of the pandemic. Full text of their […]

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