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Transfer Pricing

Latest Articles


Assurance at Stake: Difficulties of PPT in light of BEPS Action 6 and MLI

Income Tax : Explore the Principal Purpose Test (PPT) in international tax law, its impact on treaty benefits, legal uncertainty, and potential...

March 26, 2025 144 Views 0 comment Print

Future of International Taxation: OECD Global Minimum Tax

Income Tax : Learn about income tax exemptions for universities, hospitals, and educational institutions under Section 10 of the Income Tax Act...

March 11, 2025 531 Views 0 comment Print

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 1230 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 864 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 615 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 1035 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 519 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 13647 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Draft Guidance Note on Transfer Pricing Report – Section 92E

Income Tax : ICAI Releases Exposure Draft Guidance Note On Report Under Section 92E Of Income-Tax Act, 1961 (Transfer Pricing) Based on the la...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 26151 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 11814 Views 1 comment Print


Latest Judiciary


Cost Allocation and Transfer Pricing – ITAT Bangalore Ruling

Income Tax : Advocate Amardeep Soni & Advocate Harsha Soni Gemplus India Pvt. Ltd. Vs ACIT (ITAT Bangalore) A Case Study of ITAT BANGALORE...

March 19, 2025 336 Views 0 comment Print

Fresh Adjudication Ordered on TPO Adjustment in Subsidiary Transaction

Income Tax : Bangalore ITAT overturns AO's PE classification of QlikTech India, orders fresh review based on TPO order, addresses TDS and inter...

March 9, 2025 78 Views 0 comment Print

Indian Subsidiary Not a Dependent Agency PE if Transactions Are Subject to TPO Adjustment

Income Tax : ITAT Bangalore sets aside AO's decision in Qlik Tech International AB vs DCIT, addressing PE classification, TDS credit, and tax r...

March 8, 2025 162 Views 0 comment Print

Comparable cannot be excluded in Absence of Persistent Losses: ITAT Delhi

Income Tax : ITAT Delhi directs inclusion of Magma Advisory Services Ltd. in Honda R&D's comparable list, rejecting TPO's reasons and DR's func...

February 28, 2025 168 Views 0 comment Print

Protective Addition Unsustainable if Substantial Addition is Confirmed or Settled: ITAT Bangalore

Income Tax : ITAT Bangalore deletes AO’s protective addition in LM Wind Power case, citing settled MAP proceedings on IT fees and commission ...

February 27, 2025 204 Views 0 comment Print


Latest Notifications


Amendment of Safe Harbour Rules for AY 2025-26 under Section 92CB

Income Tax : CBDT notifies Income Tax (Sixth Amendment) Rules, 2025, introducing safe harbour rules for assessment year 2025-26. Full details o...

March 26, 2025 519 Views 0 comment Print

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 1410 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 3732 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 11967 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 1743 Views 0 comment Print


Extend Income-tax due dates with humane approach

January 5, 2021 53172 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 […]

Corporate and Bank Guarantee’ are ‘International Transaction’ for Transfer Pricing

January 1, 2021 1107 Views 0 comment Print

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

December 31, 2020 24402 Views 0 comment Print

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 […]

Govt extend due dates of Tax Audit/ITR/VSV Scheme/GSTR 9/9A/9C

December 30, 2020 63219 Views 25 comments Print

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 […]

Extension of Due date for TAR & IT Returns- Gujarat HC fixes next hearing on 31.12.2020

December 30, 2020 61491 Views 9 comments Print

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 […]

Extend date of filing of GSTR 9, GSTR 9C and IT returns

December 29, 2020 100668 Views 12 comments Print

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 […]

TNMM method is most appropriate method to take care of all notional interest costs

December 28, 2020 1515 Views 0 comment Print

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 requests FM to extend Income Tax due dates immediately

December 28, 2020 172386 Views 40 comments Print

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 […]

Extend Income Tax, GST, LLP, Company Law due dates

December 26, 2020 54600 Views 9 comments Print

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 […]

Extend Due date under GST and Income Tax

December 26, 2020 85776 Views 8 comments Print

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’ […]

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