Income Tax : Section 144C of IT Act, 1961 was brought through Finance Act, 2009 & introduced for orderly assessment with respect to the interna...
Income Tax : Understand penalties for under-reporting and misreporting of income in transfer pricing adjustments, as per the Income Tax Act 196...
Income Tax : Chapter X of the Income Tax Act applies solely to transactions with Associated Enterprises (AEs), excluding non-AE transactions fr...
Income Tax : Revenue authorities lack jurisdiction to question the business decisions or commercial wisdom of taxpayers in transfer pricing cas...
Income Tax : The ITAT remands BorgWarner's case on TSS, BSS, and royalty benchmarking to TPO for re-determination, questioning the segregation ...
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Income Tax : ICAI Releases Exposure Draft Guidance Note On Report Under Section 92E Of Income-Tax Act, 1961 (Transfer Pricing) Based on the la...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 : Delhi High Court upheld the ITAT’s decision, concluding that the comparability analysis must focus on functional similarity rath...
Income Tax : Delhi High Court remands Alcatel Lucent's transfer pricing case to ITAT, questioning selection of comparables in ALP determination...
Income Tax : Delhi High Court judgment on Cadence Design's appeal against the ITAT order regarding transfer pricing comparables. Key findings o...
Income Tax : ITAT Delhi remands JCB India Ltd.'s ₹166.09 crore TP adjustment for non-UK royalty payments to TPO for fresh consideration....
Income Tax : Delhi HC ruling clarifies that KPO service providers aren't comparable to ITES providers for benchmarking international transactio...
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...
Delhi High Court rules AO can’t deviate from Transfer Pricing Officer’s determined Arm’s Length Price (ALP) in international transactions, upholding assessee’s writ petition.
Learn from PCIT Vs Radhashir Jewellery Co. Pvt Ltd. case why comparing new and established businesses in transfer pricing is inappropriate. Detailed analysis provided.
Discover the intricacies of structuring cross-border mergers and acquisitions (M&A). Learn about key steps, due diligence, legal compliance, and tax considerations for successful transactions.
Country-by-Country Reporting (CbCR) is a crucial component of the transfer pricing documentation requirements introduced by the Organization for Economic Co-operation and Development (OECD) as part of the Base Erosion and Profit Shifting (BEPS) Action Plan.
Learn about Transfer Pricing compliance and assessment procedures, including ALP determination, TPO reference, DRP mechanism, APAs, and penalties for non-compliance.
Explore the significance of transfer pricing in international taxation and corporate finance. Learn about arm’s length pricing, methods for computation, and the impact of secondary adjustments.
Analysis of Maharashtra Seamless Ltd Vs DCIT case where no transfer pricing adjustment was needed as the assessee earns interest at arm’s length rate.
Delhi High Court rules in favor of Oriflame India Pvt Ltd, withdrawing TPO’s proposed income adjustments, applies TNMM over RPM. Details of the case analysis here.
Calcutta High Court dismisses PCIT’s appeal, reaffirming that the least complex party should be the tested entity in transfer pricing transactions, citing relevant precedents.
Learn about Advance Pricing Agreements (APAs) and Mutual Agreement Procedures (MAPs) in international taxation. Understand their effectiveness, compliance, and applicability in resolving transfer pricing disputes.
