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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 84 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 525 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 1209 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 825 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 1026 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 13644 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Draft Guidance Note on Transfer Pricing Report – Section 92E

Income Tax : ICAI Releases Exposure Draft Guidance Note On Report Under Section 92E Of Income-Tax Act, 1961 (Transfer Pricing) Based on the la...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 26148 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 321 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 156 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


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 186 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 1401 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 3729 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 11958 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


Advertisement, Marketing & Promotion (AMP) expense / Market Intangibles

December 26, 2020 11565 Views 0 comment Print

Over the past few years issue of Advertisement, Marketing and Promotion (‘AMP’) expenses has become very prominent in Transfer Pricing Assessments in India, wherein Indian subsidiaries which are engaged in business activities using brand name of global multi-national enterprises (‘MNEs’). Indian Revenue Authorities (IRA) argues that AMP expenses involving brand promotion service by the taxpayer […]

Extend due date for filing TAR/ITR/GSTR9/9A/9C

December 25, 2020 51006 Views 15 comments Print

All Odisha Tax Advocates Association made a Request for extension of due date for filing Tax Audit Reports (TARs), Income Tax Return (ITR) for the AY-2020-2021, statement under Vivad Se Vishwas Act, Audit and Annual Return (GSTR9, GSTR 9A, GSTR 9C)  under the GST Act. Full Text of their representation is as follows:- ALL ODISHA […]

Extend Income Tax, Companies & CGST Act compliance due dates

December 24, 2020 29385 Views 0 comment Print

Direct Taxes Professionals’ Association made a Representation to FM for extending the due dates of compliance under Income Tax Act , the Companies Act and CGST Act and widening the scope of benefit in case of cases where Assessee has been allowed relief by Hon’ble ITAT and due date of filing appeal by Department has […]

Extend Income Tax Audit & ITR Due dates for AY 2020-21

December 24, 2020 164307 Views 22 comments Print

Bhayander CA Social Group has made a Humble prayer for extension of due date u/s 139(1), section 44AB and for uploading of various audit Reports from 31st December 20 and  31st January 2021 respectively to 31st March 2021 to Smt. Nirmla Sithraman Ji, Hon’ble Union Minister of Finance. Full text of their representation is as […]

Extend due dates of Audit Reports, ITRs, GST Returns, VSV Scheme

December 24, 2020 11262 Views 2 comments Print

The Tax Bar Association, Odisha has made a prayer for extension of due dates for filing of Audit Reports, ITRs, GST Returns & Audit, Vivad Se Viswas (VSV) Scheme and other Compliances under the Direct and Indirect Tax Acts to Smt Nirmala Sitaraman, Hon,ble Finance Minister, Govt of India. THE TAX BAR ASSOCIATION BERHAMPUR, DIST-GANJAM, […]

Extend due date for filing ITR & Tax Audit Report- AY 2020-21

December 24, 2020 24315 Views 4 comments Print

Punjab Accountants Association has made a request for extension of due date for filing annual Income Tax Returns (ITR) and Tax Audited Returns (TAR) for AY 2020-21 under IT Act, 1961 to Finance Minister.  They requested to extend due date for uploading and filing Income Tax Returns and Tax Audited Reports under Section 139(1) of […]

Extend Tax/TP Audit & ITR Due dates for AY 2020-21

December 24, 2020 9966 Views 1 comment Print

Sales Tax Bar Association, Delhi has made a request to FM   for extension of due dates for Tax Audit, Transfer Pricing Audit, Statutory Audit and Income Tax Returns Filing for the Assessment Year 2020-21. Relevant Text of the Representation is as follows:- SALES TAX BAR ASSOCIATION December 21, 2020 To, Smt Nirmala Sitharaman, Hon’ble […]

Tax Professionals urge extension of dates for ITR as well as VSV & AGM

December 23, 2020 972 Views 0 comment Print

Direct Taxes Professionals Association (DTPA), Kolkata has urged Smt. Nirmala Sitharaman, Finance Minister for extension of date of furnishing of Tax Audit Report under section 44AB to 28th February, 2021 and the due date of filing ITRs of Asst Year 2020-21 in audit cases to 31st March, 2021. CA NK Goyal, President of DTPA pointed […]

Open letter for extension of Due dates under Income Tax and GST

December 23, 2020 32910 Views 4 comments Print

A letter is doing round on Social Media which is written on behalf of  All Professionals, Tax Payers and Stakeholders in which A very humble prayer for further relaxation of provisions of section 139(1) and section 44AB of the Income Tax Act, 1961 by granting extension of due date and specified date respectively etc. from […]

Extend due dates for Tax Audit & Income Tax Return filing for AY 2020-21

December 23, 2020 64773 Views 28 comments Print

Luminaires Accessories Components Manufacturers Association has requested FM to extend the due dates for Tax Audit and Income Tax Return filing to March 31, 2021 for the Assessment Year 2020-21 .  Relevant Text of their representation is as follows:- To, Smt. Nirmala Sitharaman Hon’ble Finance Minister, Ministry of Finance, North Block, New Delhi 110 001. […]

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