Income Tax : This article explains how Safe Harbour Rules under the Income-tax Act, 2025 interact with APAs, MAP provisions, and transfer prici...
Income Tax : The framework outlines mandatory disclosures and timelines for opting into safe harbour. Key takeaway: strict compliance is essent...
Income Tax : The article explains how safe harbour rules simplify transfer pricing compliance. It highlights that eligible transactions are acc...
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 : 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 : ITAT Delhi held that television channel and content owner companies could not be compared with a content distribution business. Th...
Income Tax : ITAT Mumbai held that distribution fees paid to associated enterprises could not be treated as royalty. The Tribunal followed earl...
Income Tax : ITAT Mumbai deleted the transfer pricing adjustment on management fees after finding that identical issues in the assessee’s own...
Income Tax : The ITAT held that transfer pricing adjustment was not justified where the foreign LLC’s income was already offered to tax in In...
Income Tax : ITAT Ahmedabad held that transfer pricing authorities cannot assign a NIL arm’s length price when the assessee has demonstrated ...
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...
On consideration of difficulties reported by taxpayers/stakeholders due to Covid & in e-filing of Audit reports for AY 2021-22 under the IT Act, 1961, CBDT further extends due dates for filing of Audit reports & ITRs for AY 21-22. Income Tax Audit date extended to 15 Feb 2022 and Income Tax Return date extended to […]
Randox Laboratories India Private Limited Vs ACIT (ITAT Bangalore) The facts on record reveal that the Transfer Pricing Officer under a misconception that the assessee has undertaken manufacturing activity has rejected RPM. Learned DRP has also not examined the facts in proper perspective. Rather, learned DRP has recorded an erroneous finding by stating that in […]
Association for Corporate Advisers and Executives (ACAE) made a Request for Extension of Due Dates for filing Tax Audit and Transfer Pricing (TP) Reports to as follows:- 1) The due date of furnishing of Report of Audit under any provisions of the Act, which was 30 September 2021, and extended to 15 January 2022 is […]
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 15th January, 2022 to Smt Nirmala Sitaraman Ji, Hon’ble Minister of Finance, Government of India. Voice Of CA <voiceofca@gmail.com> Wed, Jan 5, 2022 at 12:52 PM To: fmo@nic.in | Cc: […]
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, […]
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, 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 […]
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 […]
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, […]
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, […]
