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...
Honda Motorcycle & Scooter India Pvt. Ltd Vs DCIT (ITAT Delhi) With respect to the TP adjustment to the export commission, which is claimed by the assessee that it is intrinsically, looked that the main activity of manufacturing and sale of products and as such could not be identified separately for benchmarking. It is also […]
Dow Agrosciences India Private Limited Vs ACIT (ITAT Mumbai) We shall now deal with the observation of the TPO/DRP that the approval provided by the RBI would not constitute a valid CUP data, since the RBI does not take into account the transfer pricing provisions to determine the appropriate rates which can be considered as […]
Since in the financial statement for the relevant year (F.Y. 11-12), the auditor had made a clear disclosure that no revenue had been recognized on account of services rendered to SBI despite having incurred a cost of Rs. 3.2 crore and moreover, as per the matching ‘principl
The Indian Transfer Pricing Regulations (i.e. Section 92C of the Income-tax Act, 1961 read with Rule 10B of the Income-tax Rules, 1962) as well as the OECD Transfer Pricing Guidelines provide the following 5 common transfer pricing methods for evaluating the related party transactions undertaken between entities: 1. Comparable Uncontrolled Price (CUP) Method – The […]
Addition made on account of AMP expenses qualified as an ‘international transaction’ under the terms of section 92B(1) read with section 92F(v) was not justified as AMP Expenses did not qualify as an ‘international transaction’ for the purposes of section 92B firstly, there was no international transaction in the form of any agreement or arrangement on AMP expenditure incurred by assessee company; and secondly, under FAR analysis also, no such benefit from the AMP expenditure having any kind of bearing on the profits, income, losses or assets as accrued to the AE or any kind of benefit has arisen to the AE.
GOCL Corporation Ltd. Vs DCIT (ITAT Hyderabad) Learned counsel’s first and foremost argument is that a corporate guarantee is a shareholder’s activity which has been wrongly treated as an international transaction u/s.92B read with Explanation inserted by the Finance Act, 2012 with retrospective effect from 01-04-2002. He next sought to draw a distinction between the […]
Sobha City Vs ACIT (ITAT Bangalore) No addition for transfer pricing (TP) adjustment related to Specified Domestic Transactions (SDT). Conclusion: The reference to TPO for transfer pricing adjustment in respect of specified domestic transactions mentioned in clause (i) of section 92BA was not valid, as the said provision had been omitted. Accordingly, AO was directed […]
Greatship (India) Ltd. Vs DCIT (ITAT Mumbai) The assessee has further assailed the disallowance worked out by the A.O under Sec. 1 4A r.w Rule 8D, on the ground that there was no recording of an objective satisfaction by the A.O that the suo-motto disallowance offered by the assessee under Sec. 14A was not correct. […]
The Ministry of Finance’s concerns regarding possible tax avoidance practices by manipulations in the prices charged or paid, in intra-group transactions, started increasing gradually with the increase in the economic activity reported by these Multi-National Companies. These concerns prompted the then Indian Government to eventually introduce the Transfer Pricing (TP) Regulations via The Finance Bill (2001).
The Transfer Pricing Officer has simply estimated the arm’s length price of the transaction on estimate basis without applying any one of the approved methods. This cannot be accepted.
