Income Tax : Explore the Principal Purpose Test (PPT) in international tax law, its impact on treaty benefits, legal uncertainty, and potential...
Income Tax : Learn about income tax exemptions for universities, hospitals, and educational institutions under Section 10 of the Income Tax Act...
Income Tax : Learn about the amendments to Section 92CA concerning references to the Transfer Pricing Officer for determining arm's length pric...
Income Tax : New transfer pricing rules allow arm’s length price (ALP) determinations to apply for two consecutive years, reducing compliance...
Income Tax : Finance Bill 2025 allows multi-year Arm’s Length Price determination for similar transactions, reducing repetitive proceedings i...
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 : What is the procedure to approve Form 3CEB? Form uploaded by CA shall be available under For your action tab in Taxpayer’s Workl...
Income Tax : ICAI Releases Exposure Draft Guidance Note On Report Under Section 92E Of Income-Tax Act, 1961 (Transfer Pricing) Based on the la...
Income Tax : Association for Corporate Advisers and Executives (ACAE) made a Request for Extension of Due Dates for filing Tax Audit and Transf...
Income Tax : Delhi High Court held that Resale Price Method (RPM) is the most appropriate method to determine arm’s length price since assess...
Income Tax : Delhi High Court held that before undertaking a benchmarking of Advertisement, Marketing and Promotion [AMP expenses], it was incu...
Income Tax : Advocate Amardeep Soni & Advocate Harsha Soni Gemplus India Pvt. Ltd. Vs ACIT (ITAT Bangalore) A Case Study of ITAT BANGALORE...
Income Tax : Bangalore ITAT overturns AO's PE classification of QlikTech India, orders fresh review based on TPO order, addresses TDS and inter...
Income Tax : ITAT Bangalore sets aside AO's decision in Qlik Tech International AB vs DCIT, addressing PE classification, TDS credit, and tax r...
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...
Income Tax : Notification No. 46/2023-Income-Tax Dated: 26th June, 2023 regarding deemed arm's length price for assessment year 2023-2024. Le...
Tax Practitioner’s Association, Indore has made a Request for Extension of Due Dates for filing Tax Audit, Audit Reports under Income Tax Act and ITR for Assessment Year 2020-21. it has requested that due date for Tax Audit/TP Audit and Income Tax Return (Non Audit) be extended to 28th February 2021 and due date for […]
Wipro GE Healthcare Pvt. Ltd. Vs DCIT (ITAT Bangalore) In respect of transfer pricing addition made by Ld.AO. It is observed that DRP/TPO for year under consideration did not consider objections raised by assessee against comparables selected by Ld.TPO and simply followed DRP directions issued for AY 2014-15. As AY: 2014-15 has been set aside […]
PCIT Vs Yum Restaurants India Pvt. Ltd (Delhi High Court) The Court sets aside the impugned order and the corresponding orders of the AO/TPO and the DRP as regards the issue of AMP expenses and remands the issue concerning the determination of the existence of an international transaction between the Assessee and its AE involving […]
DCIT Vs Tally Solutions Pvt.Ltd. (ITAT Bangalore) Hon’ble Supreme Court in the case of DCIT v. Control Risks India (P.) Ltd. reported in 107 taxmann.com 83, had held that when TPO proposes additions to assessee’s ALP, the AO is duty bound to pass a draft assessment order. It was held by the Hon’ble Supreme Court […]
The exercise of ALP determination has to be undertaken each year separately by considering the facts and circumstances that are relevant and germane to the issue for that particular year.
Agilent Technologies India Pvt. Ltd Vs DCIT (ITAT Delhi) With respect to the Infosys technologies it is the claim of the assessee that the turnover of the above company is such a huge turnover that it is not comparable with the assessee company is software development division. For this proposition we look at page number […]
The issue under consideration is whether rejecting the benchmarking approach and methodology followed by the Appellant for determining the ALP of the transactions pertaining to purchase of fixed assets by the Appellant to its overseas AEs is justified in law?
The issue under consideration is whether overdue receivables from AEs is considered as an international transaction? ITAT direct the learned transfer pricing officer to delete the addition on account of interest on overdue receivable from associated enterprise. Accordingly ground of the appeal is allowed.
The issue under consideration is whether denial of claim of deduction u/s 10AA of the Act on transfer pricing adjustment made by the assessee voluntarily is justified in law?
The issue under consideration is whether TPO is correct in making an upward adjustment to the transfer price of the Appellant’s international transactions on account of imputation of notional interest on outstanding receivables?
