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...
Finance : The Finance Bill 2025 proposes multi-year ALP determination to reduce compliance burdens in transfer pricing. Learn about its fram...
Income Tax : Karnataka HC ruled that omission of Section 92BA(i) invalidates its application to domestic transactions, limiting transfer pricin...
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Income Tax : ICAI Releases Exposure Draft Guidance Note On Report Under Section 92E Of Income-Tax Act, 1961 (Transfer Pricing) Based on the la...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 : It was held that transactions and FAR of assessee were similar to AY 2021-22 and as per the records brought to our notice, there...
Income Tax : Respondent/assessee is a Irish company. It accordingly claimed benefits of the India-Ireland DTAA. ADIR is a wholly owned subsidia...
Income Tax : In the matter above-mentioned ITAT partly allowed the appeal filed by the assessee by remanded it back to file of TPO after consid...
Corporate Law : Delhi HC rules that SEB rates, not IEX rates, determine the market price of electricity in transfer pricing cases, dismissing Reve...
Income Tax : ITAT Delhi clarifies tax treatment for Motricity India: No levy on notional income or closure costs. Insights on Transfer Pricing ...
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...
Income Tax : In exercise of the powers conferred by the third proviso to sub-section (2) of section 92C of the Income-tax Act, 1961 (43 of 1961...
whether the 1st proviso of section 92C(4) is triggered when the income computation for deduction u/s 10AA is enhanced only in the computation of income and no such entries are made in the books of account?
Procter & Gamble Home Products Private Limited Vs DCIT (ITAT Mumbai) Main allegation of the revenue is that of non-furnishing of audited AE and non AE segmental as well as documents regarding choice of foreign entity as tested party. We also noted that any other reason for levy of penalty is for non-furnishing of audited […]
Ld. AO/ Ld. TPO/ Ld. DRP erred in using a LIBOR based interest rate to benchmark the international transaction of payment of interest on FCCDs denominated in Indian Rupees
Atos India Pvt. Ltd. Vs DCIT (ITAT Mumbai) The issue under consideration is whether the assessment initiated in the name of a non-existing entity is justified in law? ITAT states that, even after the learned DRP taking into account the fact of merger and passing order by giving directions to the learned AO in the […]
Motherson Sumi Infotech & Designs Ltd. Vs DCIT (ITAT Delhi) We find that the next issue raised is against the transfer pricing adjustment made on account of interest due on receivables outstanding. The said issue stands covered in favour of the assessee by the decision of the Tribunal in M/s. Global Logic India Ltd. for […]
The issue under consideration is whether transfer pricing adjustment as notional interest and charging it to tax, disregarding the provisions of Article 11 of India Cyprus DTAA is justified in law?
Lonsen Kiri Chemical Industries Ltd. Vs DCIT (ITAT Ahmadabad) Once the comparable company becomes the AE of the assessee in the year under consideration, then such company cannot be considered for the purpose of comparable. Case Summary: – Facts of the case: The assessee is a joint venture of two companies namely Well Prospering Ltd […]
ACIT Vs Volvo Auto (India) Private Limited (ITAT Delhi) The issue under consideration is whether CIT(A)is correct in deleting the addition made on application of CUP method for determination of ALP of international transactions by the A.O.? ITAT states that, the AO’s observation that this expenditure has been debited to the profit and loss account […]
The issue under consideration is whether disallowance of relocation expenses u/s 40(a)(i) of the Act and non granting of tax deducted at source with respect to that expense is justified in law?
The issue under consideration is whether addition made on account of Advertisement, Marketing, and Sales Promotion (AMP) transactions is justified in law?
