Income Tax : The update outlines revised compliance forms, timelines, and penalties under the new rules. It highlights a structured transition ...
Corporate Law : The issue was identifying the correct transfer pricing method for intercompany transactions. The conclusion holds that TNMM is app...
Income Tax : The Tribunal held that the Indian entity was only a distributor and not a technology or content owner. It rejected the Revenue’s...
Income Tax : This explains the new block assessment mechanism allowing ALP to apply across multiple years. It emphasizes reduced disputes and s...
Income Tax : The issue concerns replacement of Form 3CEB with a new reporting framework. The reform mandates structured reporting with enhanced...
Income Tax : CBDT signed a record number of APAs to provide clarity on transfer pricing and reduce disputes. The framework ensures advance dete...
CA, CS, CMA : KSCAA urged CBDT to extend due dates for assessees under Section 92E, citing an omission in Circular No. 15/2025 that created inco...
CA, CS, CMA : Chartered Accountants Association, Ahmedabad requests extension of ITR and audit due dates for AY 2025-26 citing compressed timeli...
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 : The issue was whether high-turnover companies can be compared with a smaller software service provider. The Tribunal held that com...
Income Tax : The Tribunal held that transfer pricing adjustment cannot survive without a final assessment order post-DRP directions. Repeating ...
Income Tax : The Tribunal held that subscription to preference shares cannot be re-characterized as loans in absence of evidence showing sham t...
Income Tax : The tribunal held that the safe harbour limit applies to valuation determined by the DVO, not just stamp duty value. It ruled in f...
Income Tax : The Court held that Tribunal remand is not a fresh reference under transfer pricing law. Hence, limitation expired earlier, entitl...
Income Tax : Notification 157/2025 sets 1% tolerance for wholesale trading and 3% for all other cases for Arm's Length Price variation for AY 2...
Income Tax : CBDT notifies Income Tax (Sixth Amendment) Rules, 2025, introducing safe harbour rules for assessment year 2025-26. Full details o...
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...
The Bombay High Court upheld the ITAT’s decision to admit an additional TP ground allowing reconsideration of AEs as the tested party. It held that no substantial question of law arose where the Tribunal remanded the issue for fresh factual examination.
The amendment clarifies how the sixty-day period under transfer pricing law must be calculated. It removes ambiguity that had led to annulment of assessments despite timely action by the TPO.
The proposed changes consolidate all IT and ITeS activities into a single category with a lower, uniform margin and a much higher turnover threshold. The key takeaway is reduced litigation risk and greater pricing certainty for large and mid-sized IT service providers.
The issue concerned valuation of royalty for bundled services. ITAT held that faulty comparables vitiated the CUP analysis and ordered fresh benchmarking.
The issue was whether a transfer pricing adjustment could survive when based solely on DRI allegations later dropped. The Tribunal held that once customs authorities exonerated the assessee, the TP adjustment had no foundation and was rightly deleted.
The case examined whether tax authorities could deny working capital adjustment despite clear prior directions of the Tribunal. The ITAT held that such directions are binding and must be implemented in letter and spirit. Once the adjustment was granted, the assessee’s margin fell within the permissible arm’s length rang
The Tribunal held that AMC services and marketing support services could not be aggregated for transfer pricing purposes. It directed separate segment-wise benchmarking based on functional differences.
The Tribunal held that a manufacturing company failing the 75% trading turnover filter applied by the TPO cannot be retained as a comparable. Dilution of the filter by the DRP only to accommodate one entity was found impermissible, leading to deletion of the comparable.
Courts have ruled that references to the TPO cannot be made mechanically. The key takeaway is strict compliance with CBDT Instruction No. 3/2016 is mandatory for jurisdiction.
The High Court held that issuing a draft assessment order under Section 144C is invalid where the Transfer Pricing Officer proposes no variation. The key takeaway is that absence of TP adjustment means the assessee is not an “eligible assessee,” making DRP proceedings without jurisdiction.
