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Transfer Pricing

Latest Articles


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 516 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 1185 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 789 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 600 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 1251 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 1020 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 516 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 13623 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Draft Guidance Note on Transfer Pricing Report – Section 92E

Income Tax : ICAI Releases Exposure Draft Guidance Note On Report Under Section 92E Of Income-Tax Act, 1961 (Transfer Pricing) Based on the la...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 26145 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 11808 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 276 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 75 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 150 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 198 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 1377 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 3723 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 11946 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 1737 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 2643 Views 0 comment Print


Tolerance Range for Transfer Pricing Notified for AY 2024-25

October 30, 2024 1020 Views 0 comment Print

CBDT sets transfer pricing tolerance range at 1% for wholesale trading and 3% for other transactions for AY 2024-25, providing clarity to taxpayers.

Revenue authorities lack jurisdiction to question commercial wisdom of taxpayer

October 19, 2024 822 Views 0 comment Print

Revenue authorities lack jurisdiction to question the business decisions or commercial wisdom of taxpayers in transfer pricing cases, ITAT rulings emphasize.

Tolerance Range for Arm’s Length Price in FY 2024-25

October 18, 2024 1377 Views 0 comment Print

CBDT sets 1% tolerance for wholesale trading and 3% for other cases under Section 92C for FY 2024-25. No adverse effects from retrospective application.

KPO Service Provider Not Comparable to ITES for Transfer Pricing Benchmarking

October 14, 2024 456 Views 0 comment Print

Delhi HC ruling clarifies that KPO service providers aren’t comparable to ITES providers for benchmarking international transactions.

No Interest Adjustment for AE if No Interest Charged from Unrelated Third Party

October 11, 2024 606 Views 0 comment Print

Delhi High Court upholds ITAT ruling in PCIT vs Global Logic India Ltd., addressing deferred payments and international transactions under Section 92B of the IT Act.

Indian Subsidiary Compensated at ALP Not a Dependent Agent PE: Delhi HC

October 11, 2024 225 Views 0 comment Print

Delhi HC rules Krones’ Indian subsidiary is not a Dependent Agent PE, dismissing the tax authority’s appeal.

Aggregation vs. Segregation Approach in Benchmarking International Transactions

September 25, 2024 540 Views 0 comment Print

The ITAT remands BorgWarner’s case on TSS, BSS, and royalty benchmarking to TPO for re-determination, questioning the segregation approach used for international transactions.

TPO must justify altering the previously accepted position on comparables

September 24, 2024 294 Views 0 comment Print

Punjab & Haryana High Court rules comparable used in ALP determination must be justified. The court dismisses Revenue’s appeal, upholding ITAT’s ruling.

Recharacterization of Transaction in Transfer Pricing

August 13, 2024 633 Views 0 comment Print

Explore the concept of transaction recharacterization in transfer pricing. Understand its rationale, benefits, and challenges in global tax systems.

Company with Turnover 10 times of Assessee’s Cannot Be Included as Comparable: ITAT Hyderabad

August 12, 2024 585 Views 0 comment Print

ITAT Hyderabad directed to exclude companies having turnover of more than or less than 10 times of the turnover of the assessee from the list of comparable. Accordingly, matter remanded back to the file of AO/ TPO.

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