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Transfer Pricing

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Safe Harbour Rules under New Income Tax Act, 2025 & Rules, 2026- Part III

Income Tax : This article explains how Safe Harbour Rules under the Income-tax Act, 2025 interact with APAs, MAP provisions, and transfer prici...

May 7, 2026 1143 Views 0 comment Print

Safe Harbour Rules under New Income Tax Act, 2025 & Rules, 2026- Part II

Income Tax : The framework outlines mandatory disclosures and timelines for opting into safe harbour. Key takeaway: strict compliance is essent...

May 1, 2026 1116 Views 0 comment Print

Safe Harbour Rules under New Income Tax Act, 2025 & Rules, 2026: Part I

Income Tax : The article explains how safe harbour rules simplify transfer pricing compliance. It highlights that eligible transactions are acc...

April 28, 2026 6519 Views 0 comment Print

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 1374 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 342 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 402 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 543 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 8184 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 2403 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 1104 Views 0 comment Print


Latest Judiciary


Channel Owner Companies not Comparable Due to Functional Differences: ITAT Delhi

Income Tax : ITAT Delhi held that television channel and content owner companies could not be compared with a content distribution business. Th...

June 9, 2026 63 Views 0 comment Print

Distribution Fee for Channel Distribution Not Royalty: ITAT Mumbai

Income Tax : ITAT Mumbai held that distribution fees paid to associated enterprises could not be treated as royalty. The Tribunal followed earl...

June 9, 2026 72 Views 0 comment Print

ITAT Deletes Management Fee TP Adjustment as Issue Was Already Decided in Earlier Years

Income Tax : ITAT Mumbai deleted the transfer pricing adjustment on management fees after finding that identical issues in the assessee’s own...

June 8, 2026 117 Views 0 comment Print

No TP Adjustment Allowed if Foreign LLC Income Was Already Taxed in India: ITAT Delhi

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...

June 8, 2026 153 Views 0 comment Print

TP Adjustment Quashed as Benefit Test Cannot Justify NIL ALP After Service Receipt Is Established

Income Tax : ITAT Ahmedabad held that transfer pricing authorities cannot assign a NIL arm’s length price when the assessee has demonstrated ...

June 8, 2026 102 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 5121 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 4971 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 3357 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 4650 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 12819 Views 0 comment Print


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

January 5, 2022 23148 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 23187 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 16194 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 27969 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 […]

Request to extend due date for filing ITR & TARs | AY 2021-22

December 27, 2021 53682 Views 7 comments Print

All Odisha Tax Advocates Association has requested FM to consider the genuine difficulties of the assessees and Tax Professionals and be generous to pass an order to extend the due date of filing of the return of income of the assessees to 28/02/2022 in place of 31/12/2021 and the TARs from 15/01/2022 to 28/02/2022 and […]

Extend due dates of ITR & Tax audit report submission

December 26, 2021 27159 Views 4 comments Print

Chandigarh Chartered Accountants Taxation Association has made a representation to Finance Minister for Extension of due dates of Income tax returns & Submission of Tax audit reports for FY 2020-21 (AY 2021-22) in view of Practical difficulties faced by taxpayers & tax professionals in filing Income tax returns, tax audit form. Full Text of their […]

Bright-line test for TP adjustment on AMP expenditure is unsustainable in law

December 25, 2021 7926 Views 0 comment Print

Timex Group India Ltd. Vs ACIT (ITAT Delhi) Brief facts of the case are that the assessee is a company engaged in the business of manufacture, trading, sale and servicing of quartz, analogue and digital watches and watch components; manufacture and sale of plastic components, tools and moulds; and rendering information technology and financial support […]

ITeS’ functionally not comparable to Knowledge Process Outsourcing

December 25, 2021 2478 Views 0 comment Print

The assessee company provides back office support services to AEs with the help of tools, infrastructure and training provided by the AEs which is different than the functions of the KPO.

ITAT deletes addition for royalty – Dabur India gets relief

December 25, 2021 2229 Views 0 comment Print

Dabur India Ltd. Vs ACIT (ITAT Delhi) We have heard both the parties and perused the relevant material available on record. As regards to agreement with Dabur Nepal Pvt. Ltd. Nepal, it is pertinent to note that the issue stands covered in favour of the assessee by the order of the Tribunal in the asssessee’s […]

Representation for extension of Income Tax due dates to Finance Ministry

December 25, 2021 33837 Views 3 comments Print

Synopsis of the Representation by ‘Bhayandar CA Social Group’ made for extension of due dates – To the Finance Ministry on 24-12-2021 We have not asked any extension of the due dates. We have asked for our fundamental right to be professionally engaged in the profession of the Chartered Accountancy by having seamless access to […]

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