Income Tax : Learn about the amendments to Section 92CA concerning references to the Transfer Pricing Officer for determining arm's length pric...
Income Tax : New transfer pricing rules allow arm’s length price (ALP) determinations to apply for two consecutive years, reducing compliance...
Income Tax : Finance Bill 2025 allows multi-year Arm’s Length Price determination for similar transactions, reducing repetitive proceedings i...
Finance : The Finance Bill 2025 proposes multi-year ALP determination to reduce compliance burdens in transfer pricing. Learn about its fram...
Income Tax : Karnataka HC ruled that omission of Section 92BA(i) invalidates its application to domestic transactions, limiting transfer pricin...
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Income Tax : ICAI Releases Exposure Draft Guidance Note On Report Under Section 92E Of Income-Tax Act, 1961 (Transfer Pricing) Based on the la...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 : 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...
Income Tax : Respondent/assessee is a Irish company. It accordingly claimed benefits of the India-Ireland DTAA. ADIR is a wholly owned subsidia...
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...
Corporate Law : Delhi HC rules that SEB rates, not IEX rates, determine the market price of electricity in transfer pricing cases, dismissing Reve...
Income Tax : ITAT Delhi clarifies tax treatment for Motricity India: No levy on notional income or closure costs. Insights on Transfer Pricing ...
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...
PCI Limited Vs ACIT (ITAT Delhi) The Assessing Officer made the addition of Rs.73,69,830/-qua Transfer Pricing Adjustment on account of providing corporate guarantee by the Assessee to its overseas associated enterprises companies, namely, PCI Asia Pacific Pvt. Ltd. and PCI Middle East FZE by treating the interest rate of 1.3% based on average fees charged […]
Govt notifies extend due dates of Tax Audit/ITR/VSV Scheme vide Notification No. 93/2020-Income Tax dated 31st December, 2020 MINISTRY OF FINANCE (Department of Revenue) (CENTRAL BOARD OF DIRECT TAXES) Notification No. 93/2020-Income Tax New Delhi, the 31st December, 2020 S.O. 4805(E).—In exercise of the powers conferred by sub-section (1) of section 3 of the Taxation […]
In view of the continued challenges faced by taxpayers in meeting statutory compliances due to outbreak of COVID-19, the Govt further extends the dates for various compliances. Due date for filing ITR (Non tax audit) extended till 10/01/2021. Due date for filing Tax Audit and TP Audit Report extended till 15/01/2021. Due date for filing […]
Gujarat Federation of Tax Consultants Vs Union of India (Gujarat High Court) Gujarat High Court heard petition for extension of due dates in TAR and ITR for A Y 2020-21 on today. Court issued notice and fix next hearing on tomorrow. FULL TEXT OF THE HIGH COURT ORDER/JUDGEMENT Heard Mr. S. N. Soparkar, learned Senior […]
A. P. Tax Bar Association, Vijayawada has made a representation to Smt. Nirmala Sitaraman, Hon’ble Finance Minister and requested her for extending the time limit for filing GSTR 9 and 9C returns as also the Income Tax returns for the assessment years 2020-21 which would be beneficial to both individuals, firms and companies and also […]
Gimpex Pvt. Ltd. Vs ACIT (ITAT Chennai) There is no dispute with regard to the fact that receivables is included under the definition of international transactions by amending section 92B by the Finance Act, 2012 w.e.f. 01.04.2002. Therefore, we are of the considered view that there is no merit in the arguments advanced by the […]
ICAI has sent a Humble reminder to FM to for immediate consideration of their request(s) for extension of various due dates under Income-tax Act, 1961 especially Tax Audit Reports and related returns and Income Tax Return Forms for AY 2020-21. ICAI has also made an representation earlier on 13th December 2020. Full text of the […]
BJP Economic Cell, Rajasthan has requested Hon’ble Union Finance Mister to extend due dates of ITR for person (Non-Audit) (FY 2019-20), Tax Audit Reports (FY 2019-20), ITR for other persons (FY 2019-20), GST Annual Return GSTR9/9C/4 (FY 2018-19), GST Annual Return GSTR9/9C/4 (FY 2019-20), Vivad Se Vishwas Scheme, 2020, Companies Fresh Start Scheme. 2020 and […]
Hyderabad Chartered Accountants’ Society has requested for extension of various due dates under Income-tax Act, 1961 for AY 2020-21 and for filing the Annual Reconciliation Statement (GSTR 9C) along with the annual return (GSTR 9) for financial years 2018-2019 & 2019-2020. Full text of their representation to finance minister is as follows:- Hyderabad Chartered Accountants’ […]
Over the past few years issue of Advertisement, Marketing and Promotion (‘AMP’) expenses has become very prominent in Transfer Pricing Assessments in India, wherein Indian subsidiaries which are engaged in business activities using brand name of global multi-national enterprises (‘MNEs’). Indian Revenue Authorities (IRA) argues that AMP expenses involving brand promotion service by the taxpayer […]
