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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 873 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 609 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 525 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 978 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 342 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 927 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 13548 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Draft Guidance Note on Transfer Pricing Report – Section 92E

Income Tax : ICAI Releases Exposure Draft Guidance Note On Report Under Section 92E Of Income-Tax Act, 1961 (Transfer Pricing) Based on the la...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 11784 Views 1 comment Print


Latest Judiciary


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 96 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 87 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 438 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 243 Views 0 comment Print

Omission of Section 92BA(1) from 1/4/2017 Deems it Nonexistent from Insertion Date

Income Tax : Karnataka HC decision on transfer pricing adjustments and Section 92BA amendments in the PCIT vs TT Steel Service India Pvt. Ltd. ...

January 7, 2025 315 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 1188 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 3678 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 11865 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 1719 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 2616 Views 0 comment Print


Penalty u/s 271G untenable as no transfer pricing adjustment possible due to omission of section 92BA(i): ITAT Mumbai

August 1, 2024 204 Views 0 comment Print

ITAT Mumbai held that no transfer pricing adjustment could have been made in the hands of assessee on account of ALP of specified domestic transactions as section 92BA(i) of Income Tax Act was omitted. Thus, since provisions of section 92D are not applicable, penalty u/s. 271G of the Income Tax Act untenable.

UAE Transfer Pricing Compliance Dates

July 31, 2024 1149 Views 0 comment Print

Discover the key compliance dates for UAE transfer pricing regulations under the new corporate tax law effective from 1 June 2023. Learn more now!

Transfer Pricing Compliance Chart For FY 2023-24 (AY 2024-25)

July 30, 2024 32991 Views 0 comment Print

India’s Transfer Pricing regulations for FY 2023-24 (AY 2024-25) – This detailed chart lists key activities, legal sections, required forms, and deadlines for easy reference.

Budget 2024: TPO can evaluate SDTs not reported by taxpayers

July 26, 2024 465 Views 0 comment Print

From April 2025, TPOs can determine ALP for SDTs not initially referred or reported. This ensures accurate adjustments and compliance with new regulations.

Payment by Indian Entity to AE Abroad Not ‘FTS’ if No Technical Skill Provided: Bangalore ITAT

July 4, 2024 468 Views 0 comment Print

Learn how ITAT Bangalore ruled in favor of Herbalife India on technical service payments, clarifying FTS under India-USA DTAA. Detailed analysis and full judgment inside.

Demystifying Transfer Pricing

June 29, 2024 840 Views 0 comment Print

Learn about transfer pricing, its importance, methods, documentation, penalties for non-compliance, and advanced pricing agreements in India.

Benchmarking Managerial Compensation in UAE: Understanding Transfer Pricing Framework

June 25, 2024 1890 Views 0 comment Print

Understand the UAE’s transfer pricing framework and benchmarks for managerial compensation under the new corporate tax law. Ensure compliance with Article 36 requirements.

ITAT Directs 6% SBI Rate on Delayed Payments in International Transactions

June 21, 2024 468 Views 0 comment Print

Explore the ITAT Hyderabad’s decision on interest as an international transaction in Clinasia Labs Pvt Ltd vs ITO case. Detailed analysis and conclusions provided.

RPM is most appropriate method When No Value Addition Before Resale

June 16, 2024 1080 Views 0 comment Print

ITAT Delhi rules RPM as the best method for benchmarking solar goods purchases in the D Light Energy P. Ltd. vs Assessing Officer case. Read the detailed analysis.

ITAT Rulings on TP Adjustments, ESOP Expenses & Section 14A Disallowance

June 11, 2024 525 Views 0 comment Print

Tribunal upholds CIT(A) decisions in DCIT Vs Astral Limited case, offering key insights on TP adjustments, ESOP expenses, and Section 14A disallowance.

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