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Transfer Pricing

Latest Articles


India Transfer Pricing- Due Dates for Compliance for Tax Year 2026-27

Income Tax : The update outlines revised compliance forms, timelines, and penalties under the new rules. It highlights a structured transition ...

April 17, 2026 201 Views 0 comment Print

Transfer Pricing MAM Selection: Germany–India Subsidiary Case (TNMM Approach)

Corporate Law : The issue was identifying the correct transfer pricing method for intercompany transactions. The conclusion holds that TNMM is app...

April 14, 2026 120 Views 0 comment Print

Netflix India Wins ₹444 Crore Transfer Pricing Fight

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...

April 13, 2026 324 Views 0 comment Print

Transfer Pricing under Income Tax Act: ALP, AEs & Compliance Framework

Income Tax : This explains the new block assessment mechanism allowing ALP to apply across multiple years. It emphasizes reduced disputes and s...

April 9, 2026 636 Views 0 comment Print

Form No. 48: Transfer Pricing Certification under Income-tax Act, 2025

Income Tax : The issue concerns replacement of Form 3CEB with a new reporting framework. The reform mandates structured reporting with enhanced...

April 6, 2026 978 Views 0 comment Print


Latest News


Record 219 APAs Signed Due to Rising Need for Transfer Pricing Certainty

Income Tax : CBDT signed a record number of APAs to provide clarity on transfer pricing and reduce disputes. The framework ensures advance dete...

April 1, 2026 228 Views 0 comment Print

KSCAA Seeks Parity in ITR Due Date Extension for Transfer Pricing Assessees

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...

November 3, 2025 480 Views 0 comment Print

CA Association Seeks Extension for ITR, Tax and TP Audit Dates

CA, CS, CMA : Chartered Accountants Association, Ahmedabad requests extension of ITR and audit due dates for AY 2025-26 citing compressed timeli...

September 10, 2025 8139 Views 1 comment Print

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 2199 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 1044 Views 0 comment Print


Latest Judiciary


Companies with significantly higher turnover are not comparable: ITAT Bangalore

Income Tax : The issue was whether high-turnover companies can be compared with a smaller software service provider. The Tribunal held that com...

April 2, 2026 315 Views 0 comment Print

Missed DRP timeline kills TP addition; ₹288 Cr share capital upheld

Income Tax : The Tribunal held that transfer pricing adjustment cannot survive without a final assessment order post-DRP directions. Repeating ...

March 27, 2026 426 Views 0 comment Print

ITAT Mumbai Rejects TP Adjustment as Preference Shares Cannot Be Treated as Loans Without Evidence

Income Tax : The Tribunal held that subscription to preference shares cannot be re-characterized as loans in absence of evidence showing sham t...

March 24, 2026 411 Views 0 comment Print

ITAT Allows 10% Safe Harbour on DVO Valuation Due to Estimation Nature of Property Values

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...

March 21, 2026 411 Views 0 comment Print

United Spirits Case: Remand in TP Case Does Not Extend Section 153 Limitation

Income Tax : The Court held that Tribunal remand is not a fresh reference under transfer pricing law. Hence, limitation expired earlier, entitl...

March 21, 2026 267 Views 0 comment Print


Latest Notifications


Income Tax ALP Tolerance Range for AY 2025-26 Notified

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...

November 6, 2025 4779 Views 0 comment Print

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 25, 2025 4596 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 3168 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 4497 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 12654 Views 0 comment Print


Request to Extend Due Dates for filing Tax & Transfer Pricing Audit

January 7, 2022 8859 Views 1 comment Print

Chamber of Tax Consultants has made a Request for Extension of Due Dates for filing Tax Audit and Transfer Pricing Reports to Smt. Nirmala Sitharaman, Hon’ble Finance Minister,Ministry of Finance. Full text of their representation is as follows:- The Chamber of Tax Consultants Date: 7th January, 2022 To, 1. Smt. Nirmala Sitharaman, Hon’ble Finance Minister, […]

Request to extend due date of Tax Other Audit Reports

January 7, 2022 5289 Views 0 comment Print

Tax Bar Association, Jodhpur has made a Request for extension of due date of Tax Audit Report and Other Reports for a month. Relevant Text of their representation is as follows:- TAX BAR ASSOCIATION JODHPUR (Rajasthan) Date: 07th January, 2022 To, Hon’ble Finance Minister. Ministry of Finance New Delhi Hon’ble Madam, Greetings of the Day! […]

ICAI request waiver of Penalty for delay in filing Income Tax Audit Reports

January 6, 2022 11682 Views 1 comment Print

ICAI, Indore has requested CBDT Chairman to consider waiver of penalty for delay in furnishing of Report of Audit under any provision of the Income-tax Act, 1961 for the A. Y. 2021-22. Full Text of their representation is as follows:- THE INSTITUTE OF CHARTERED ACCOUNTANTS OF INDIA (Set up by an Act of parliament) Indore (CIRC) Indore/2021-22/Rep-1 […]

TPO erred in holding ALP at nil on the ground that relevant documents not been submitted

January 5, 2022 1668 Views 0 comment Print

PPG Coatings India Pvt. Ltd. Vs DCIT (ITAT Mumbai) It was submitted that SAP license was purchased by the AE at Netherland in bulk quantities. A copy of the agreement entered into between the said AE and the third party along with the copy of the debit note raised by the AE was submitted. It […]

Performance incentive not paid before due date of return not allowable

January 5, 2022 15609 Views 0 comment Print

Hyundai Motor India Ltd. Vs ACIT (ITAT Chennai) The next issue that came up for consideration from ground No. 6 of assessee appeal is disallowance u/s.43B(c) of the Act, in respect of performance incentive paid to employees. Facts with regard to impugned dispute are that for the financial year relevant to the assessment year 2016-17, […]

Memorandum for Extension of Due Date for filing of Income Tax Audit Report

January 5, 2022 24162 Views 4 comments Print

Direct Taxes Professionals’ Association (DTPA), Kolkata has made a representation for Extension of Due Date for filing of Income Tax Audit Report under Income Tax Act to Hon’ble Smt. Nirmala Sitharaman Ji, Union Minister of Finance, Ministry of Finance. Full Text of her representation is as follows:-  DIRECT TAXES PROFESSIONALS’ ASSOCIATION Income Tax Building, 3, […]

Request for Section 234F Late Fees waiver & extension of TAR/ITR due dates

January 5, 2022 23073 Views 0 comment Print

Tax Advocates Association Gujarat has made a Request for waiver of Late Fees under section  234 F of the Income Tax Act, 196 and extension of DUe Date for filing of audit report & audited Income Tax Return for A.Y. 2021-22. Full Text of their representation is as follows:- Tax Advocates Association Gujarat To, 1. […]

Representation regarding Extension of Income Tax Due Dates

December 31, 2021 23067 Views 13 comments Print

District Taxation Bar Association (Direct Taxes), Ludhiana has made a representation to FM Smt. Nirmala Sitharaman Ji and  requested for extension of time for filing income tax returns in the light of the issues and problems being faced by the Members & the Assessees. District Taxation Bar Association (Direct Taxes), Ludhiana Dated: 27.12.2021 To Smt. […]

Glitches on Income Tax Portal & request for due date extension

December 28, 2021 16131 Views 2 comments Print

The Chamber Of Tax Consultants has made a representation to Smt. Nirmala Sitharaman on Technical glitches in the Income-tax e-fining portal and  Requested for Extension of due dates for filing Return of Income. Full text of their representation is as follows:- THE CHAMBER OF TAX CONSULTANTS Date: 27th December, 2021 To, 1. Smt. Nirmala Sitharaman, […]

Request to Extend due dates under Income Tax Act & Companies Act

December 28, 2021 27921 Views 1 comment Print

Delhi Tax Bar Association has made a representation to Hon’ble FM Nirmala Sitharaman Ji and requested for Extension of Due Dates for Submission of Income Tax Returns and various Audit Reports under the Income Tax Act and Companies Act. DELHI TAX BAR ASSOCIATION Formerly Bar Association (Income Tax) (ESTD. 1954-55) G-09, CENTRAL REVENUE BUILDING, INDRAPRASTHA […]

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