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Transfer Pricing

Latest Articles


Recharacterization of Transaction in Transfer Pricing

Income Tax : Explore the concept of transaction recharacterization in transfer pricing. Understand its rationale, benefits, and challenges in g...

August 13, 2024 216 Views 0 comment Print

UAE Transfer Pricing Compliance Dates

Income Tax : Discover the key compliance dates for UAE transfer pricing regulations under the new corporate tax law effective from 1 June 2023....

July 31, 2024 753 Views 0 comment Print

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

Income Tax : India's Transfer Pricing regulations for FY 2023-24 (AY 2024-25) - This detailed chart lists key activities, legal sections, requi...

July 30, 2024 17139 Views 0 comment Print

Demystifying Transfer Pricing

CA, CS, CMA : Learn about transfer pricing, its importance, methods, documentation, penalties for non-compliance, and advanced pricing agreement...

June 29, 2024 477 Views 0 comment Print

Benchmarking Managerial Compensation in UAE: Understanding Transfer Pricing Framework

Income Tax : Understand the UAE's transfer pricing framework and benchmarks for managerial compensation under the new corporate tax law. Ensure...

June 25, 2024 840 Views 0 comment Print


Latest News


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 243 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 12312 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Draft Guidance Note on Transfer Pricing Report – Section 92E

Income Tax : ICAI Releases Exposure Draft Guidance Note On Report Under Section 92E Of Income-Tax Act, 1961 (Transfer Pricing) Based on the la...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 25863 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 11673 Views 1 comment Print

Request to extend due dates of Tax Audit Report & Other forms

Income Tax : Voice Of CA has made a Request for Extension of specified date of filing Tax Audit Report and other forms falling due on or before...

January 7, 2022 27873 Views 12 comments Print


Latest Judiciary


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

Income Tax : ITAT Hyderabad directed to exclude companies having turnover of more than or less than 10 times of the turnover of the assessee fr...

August 12, 2024 156 Views 0 comment Print

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

Income Tax : ITAT Mumbai held that no transfer pricing adjustment could have been made in the hands of assessee on account of ALP of specified ...

August 1, 2024 111 Views 0 comment Print

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

Income Tax : Learn how ITAT Bangalore ruled in favor of Herbalife India on technical service payments, clarifying FTS under India-USA DTAA. Det...

July 4, 2024 372 Views 0 comment Print

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

Income Tax : Explore the ITAT Hyderabad's decision on interest as an international transaction in Clinasia Labs Pvt Ltd vs ITO case. Detailed a...

June 21, 2024 381 Views 0 comment Print

RPM is most appropriate method When No Value Addition Before Resale

Income Tax : ITAT Delhi rules RPM as the best method for benchmarking solar goods purchases in the D Light Energy P. Ltd. vs Assessing Officer ...

June 16, 2024 903 Views 0 comment Print


Latest Notifications


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 2931 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 10773 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 1527 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 2370 Views 0 comment Print

Safe Harbour rules for AY 2022-2023 – Income tax Act, 1961

Income Tax : Safe Harbour rules for AY 2022 2023 | Income tax Act, 1961 | Notification No. 66/2022-Income-Tax | Dated: 17th June, 2022 |  CBDT...

June 17, 2022 13707 Views 0 comment Print


Transfer Pricing: Part 1 – Analysis, Methods and Compliance

March 22, 2024 1335 Views 0 comment Print

Explore the significance of transfer pricing in international taxation and corporate finance. Learn about arm’s length pricing, methods for computation, and the impact of secondary adjustments.

If Assessee Earns Interest at Arm’s Length Rate no Transfer pricing Adjustment Needed

March 20, 2024 264 Views 0 comment Print

Analysis of Maharashtra Seamless Ltd Vs DCIT case where no transfer pricing adjustment was needed as the assessee earns interest at arm’s length rate.

Significant differences in product segments & marketing strategies: ITAT excludes comparable

March 19, 2024 237 Views 0 comment Print

Delhi High Court rules in favor of Oriflame India Pvt Ltd, withdrawing TPO’s proposed income adjustments, applies TNMM over RPM. Details of the case analysis here.

In Transfer pricing associated enterprises can be selected as a tested party: Calcutta HC

March 19, 2024 219 Views 0 comment Print

Calcutta High Court dismisses PCIT’s appeal, reaffirming that the least complex party should be the tested entity in transfer pricing transactions, citing relevant precedents.

Comparative analysis of Mutual agreement Procedure & Advance pricing agreement

March 16, 2024 822 Views 0 comment Print

Learn about Advance Pricing Agreements (APAs) and Mutual Agreement Procedures (MAPs) in international taxation. Understand their effectiveness, compliance, and applicability in resolving transfer pricing disputes.

Transfer Pricing: Comparability Analysis and Functional Analysis

March 9, 2024 1662 Views 0 comment Print

Maximize transfer pricing accuracy with our guide on Comparability and Functional Analysis, aligning transactions with the arm’s length principle for compliance and strategic insights.

Action Plans 8-10: Aligning Transfer Pricing Outcomes with Value Creation 

March 7, 2024 543 Views 0 comment Print

Actions 8-10 of the Base Erosion and Profit Shifting (BEPS) agenda aim to address misapplications of international transfer pricing rules. These misapplications result in profit allocations not aligned with the economic activities generating them.

Action 13 of BEPS Action Plan on Transfer Pricing Documentation

March 7, 2024 606 Views 0 comment Print

Explore the comprehensive requirements of Action 13 of the BEPS Action Plan on transfer pricing documentation, including local file, master file, and country-by-country reporting. Learn about implementation thresholds and India’s incorporation of these standards.

Exclusion of Comparables Unjustified if Financial Data Can Be Reasonably Extrapolated: ITAT

March 3, 2024 546 Views 0 comment Print

ITAT Mumbai rules that comparables cannot be excluded if their financial data can be reasonably extrapolated, in Syngenta Services Private Limited’s case.

Evolution of OECD’s concept of Harmful Tax Practices: From 1998 Report to BEPS Action 5 Approach

February 21, 2024 402 Views 0 comment Print

Explore the evolution of harmful tax practices from the OECD’s 1998 report to the BEPS Action 5 approach, focusing on transparency, substantial activity requirements, and the eradication of harmful regimes.

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