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 : The Tribunal held that the Indian entity was only a distributor and not a technology or content owner. It rejected the Revenue’s...
Income Tax : This explains the new block assessment mechanism allowing ALP to apply across multiple years. It emphasizes reduced disputes and s...
Income Tax : The issue concerns replacement of Form 3CEB with a new reporting framework. The reform mandates structured reporting with enhanced...
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 : The issue was whether high-turnover companies can be compared with a smaller software service provider. The Tribunal held that com...
Income Tax : The Tribunal held that transfer pricing adjustment cannot survive without a final assessment order post-DRP directions. Repeating ...
Income Tax : The Tribunal held that subscription to preference shares cannot be re-characterized as loans in absence of evidence showing sham t...
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...
Income Tax : The Court held that Tribunal remand is not a fresh reference under transfer pricing law. Hence, limitation expired earlier, entitl...
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...
Evolving Systems Networks India Pvt. Ltd. Vs DCIT (ITAT Bangalore) The only other ground pressed was with regard to the action of the TPO in treating provision for bad and doubtful debts as part of non operating expense while computing operating margin of comparables. Karnataka High Court has also taken a view in the case […]
Transfer pricing refer to the strategies which determine the trading price for goods or services between the related parties which is defined under Section 2(76) of Companies act 2016 and covered in AS 18 and IND AS 24. Transfer pricing empowers changes in pricing. Transactions under Transfer pricing between related entities in different countries is one of the most important and complex issue of taxation which global companies face.
Wieland Metals India Private Ltd. Vs ITO (ITAT bangalore) Issue before us is with regard to TP adjustment by applying TNMM by the TPO instead of CUP method adopted by the assessee as most appropriate method in respect of determining of ALP of manufacturing segment. As seen from the details of international transactions, the assessee […]
Increase in brand value due to use of foreign AEs brand name in Taxpayer’s products cannot be considered as provision of services, as per international transaction definition u/s 92B of the Income Tax Act, 1961.
Bennett Coleman & Co Ltd Vs DCIT (ITAT Mumbai) What is being termed as a guarantee is the obligation of the assessee company, in terms of “agreement for the sale and purchase of entire equity share capital of Virgin Radion Holdings Ltd UK” dated 30thMay 2008, which has led to the actual crystallization of sale […]
The Finance Ministry vide Circular no. 17/2021 dated 09 September, 2021 announced extensions to the deadline for the filing of the Income-tax Returns, as well as some other allied compliances for the Assessment Year 2021-22: Sr. No. Particulars Original Due Date Extended to vide earlier Circular no.9/2021 Now Extended to vide Latest Circular no. 17/2021 […]
Conduct of the assessee in complying with 12 items out of 16 items as called for by the TPO can be considered to be reasonable and the act cannot be held to be an unreasonable act, but can be considered as a reasonable act of an organization acting with prudence under normal circumstances without negligence or inaction or want of bonafides.
An interest-free debt funding of an overseas company in the nature of a special purpose vehicle (SPV), with a corresponding obligation to use it for the purpose of acquisition of a target company abroad, could not be compared with a loan simpliciter, and be, subjected to an arm’s length price adjustment on account of notional interest on a loan by assessee company to its fully owned foreign subsidiary as balances reflected on account of exchange difference for notional conversions could not be treated as outstanding dues.
The related party transactions have always been under the close scanner of the Tax Authorities. Owing to the inherent nature of such transactions it is believed that such transactions are by far the most convenient way of shifting profits and accordingly subjected to detailed scrutiny by the Tax Authorities. The international transactions have been under […]
Hitachi Hi Rel Power Electronics Pvt. Ltd. Vs DCIT (Gujarat High Court) A.O. could be said to have overlooked or rather ignored the jurisdictional requirement of a satisfaction in accordance with para 3.4 of the instruction No.3 of 2016 referred to above that there ought to be an income or potential of an income arising […]
