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Transfer Pricing

Latest Articles


Structuring Cross-Border Mergers and Acquisitions

Income Tax : Discover the intricacies of structuring cross-border mergers and acquisitions (M&A). Learn about key steps, due diligence, legal c...

April 1, 2024 471 Views 0 comment Print

Country-by-Country Reporting (CbCR)

Income Tax : Country-by-Country Reporting (CbCR) is a crucial component of the transfer pricing documentation requirements introduced by the Or...

March 31, 2024 906 Views 0 comment Print

Transfer Pricing – Part 2 – Compliance and Assessment Procedures

Income Tax : Learn about Transfer Pricing compliance and assessment procedures, including ALP determination, TPO reference, DRP mechanism, APAs...

March 28, 2024 2106 Views 0 comment Print

Transfer Pricing: Part 1 – Analysis, Methods and Compliance

Income Tax : Explore the significance of transfer pricing in international taxation and corporate finance. Learn about arm's length pricing, me...

March 22, 2024 822 Views 0 comment Print

Comparative analysis of Mutual agreement Procedure & Advance pricing agreement

Income Tax : Learn about Advance Pricing Agreements (APAs) and Mutual Agreement Procedures (MAPs) in international taxation. Understand their e...

March 16, 2024 366 Views 0 comment Print


Latest News


FAQ’s on filing of Income Tax Form 3CEB

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...

October 28, 2022 12027 Views 0 comment Print

Draft Guidance Note on Transfer Pricing Report – Section 92E

Income Tax : ICAI Releases Exposure Draft Guidance Note On Report Under Section 92E Of Income-Tax Act, 1961 (Transfer Pricing) Based on the la...

July 21, 2022 25623 Views 1 comment Print

ACAE Requested due date extension for filing Tax & TP Audit

Income Tax : Association for Corporate Advisers and Executives (ACAE) made a Request for Extension of Due Dates for filing Tax Audit and Transf...

January 7, 2022 11607 Views 1 comment Print

Request to extend due dates of Tax Audit Report & Other forms

Income Tax : Voice Of CA has made a Request for Extension of specified date of filing Tax Audit Report and other forms falling due on or before...

January 7, 2022 27804 Views 12 comments Print

Request to Extend Due Dates for filing Tax & Transfer Pricing Audit

Income Tax : Chamber of Tax Consultants has made a Request for Extension of Due Dates for filing Tax Audit and Transfer Pricing Reports to Smt....

January 7, 2022 8553 Views 1 comment Print


Latest Judiciary


AO Must Adhere to TPO’s ALP in International Transactions: Delhi HC

Income Tax : Delhi High Court rules AO can't deviate from Transfer Pricing Officer's determined Arm's Length Price (ALP) in international trans...

April 11, 2024 210 Views 0 comment Print

Transfer Pricing: Comparing New Assessees with Established Businesses is Inappropriate

Income Tax : Learn from PCIT Vs Radhashir Jewellery Co. Pvt Ltd. case why comparing new and established businesses in transfer pricing is inapp...

April 3, 2024 288 Views 0 comment Print

If Assessee Earns Interest at Arm’s Length Rate no Transfer pricing Adjustment Needed

Income Tax : Analysis of Maharashtra Seamless Ltd Vs DCIT case where no transfer pricing adjustment was needed as the assessee earns interest a...

March 20, 2024 165 Views 0 comment Print

Significant differences in product segments & marketing strategies: ITAT excludes comparable

Income Tax : Delhi High Court rules in favor of Oriflame India Pvt Ltd, withdrawing TPO's proposed income adjustments, applies TNMM over RPM. D...

March 19, 2024 144 Views 0 comment Print

In Transfer pricing associated enterprises can be selected as a tested party: Calcutta HC

Income Tax : Calcutta High Court dismisses PCIT's appeal, reaffirming that the least complex party should be the tested entity in transfer pric...

March 19, 2024 99 Views 0 comment Print


Latest Notifications


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 2433 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 9534 Views 0 comment Print

Deemed Arm’s Length Price for Assessment Year 2023-2024

Income Tax : Notification No. 46/2023-Income-Tax Dated: 26th June, 2023  regarding deemed arm's length price for assessment year 2023-2024. Le...

June 26, 2023 1344 Views 0 comment Print

Tolerance Band for AY 2022-23 in case of wholesale trading & others

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...

June 28, 2022 2127 Views 0 comment Print

Safe Harbour rules for AY 2022-2023 – Income tax Act, 1961

Income Tax : Safe Harbour rules for AY 2022 2023 | Income tax Act, 1961 | Notification No. 66/2022-Income-Tax | Dated: 17th June, 2022 |  CBDT...

June 17, 2022 13395 Views 0 comment Print


ALP of guarantee commission determined @0.3523% instead of 1.25%

November 20, 2023 480 Views 0 comment Print

ITAT Mumbai held that Arm’s Length Price (ALP) of guarantee commission was determined at the rate of 0.3523% instead of 1.25%.

Comparability for determining ALP lost as only comparable chosen by DRP fails

November 15, 2023 393 Views 0 comment Print

ITAT Mumbai held that once only comparable as chosen by DRP fails, then same loses the comparability for determining the ALP.

Delhi HC Upholds ITAT’s Decision on Comparables for Arm’s Length Price

November 14, 2023 504 Views 0 comment Print

Delhi High Court supports ITAT’s verdict on the selection of comparables for determining the Arm’s Length Price of an international transaction. Get insights on PCIT vs Chrys Capital

AMP Expenses Not an International Transaction for transfer pricing: Delhi HC

November 14, 2023 381 Views 0 comment Print

Delhi High Court upholds ITAT’s decision: Advertising, Marketing, and Promotion (AMP) expenses by Wrigley India Pvt. Ltd. not considered an international transaction.

Government Shareholders Not Automatically Considered Related Parties

November 12, 2023 249 Views 0 comment Print

In a landmark ruling, the Delhi High Court held that government shareholders are not automatically considered related parties under Section 92E of the Income Tax Act, 1961. This decision has significant implications for companies with government shareholding.

CUP Method Rejection Unwarranted for Uniform Hourly Charges to AEs & Third Parties

November 4, 2023 216 Views 0 comment Print

ITAT that as long as the charges for hourly services provided by appellant were uniform to AEs and third parties, rejection of CUP method was unwarranted.

Penalties for not Maintaining Documents for Specified Domestic Transactions

November 3, 2023 6162 Views 0 comment Print

Penalties for failing to maintain records of specified domestic transactions. Learn about arm’s length pricing & essential document requirements

Delhi HC: Exclusion of OTL Comparable – ITAT to Decide

November 2, 2023 327 Views 0 comment Print

The Delhi High Court directs the ITAT to reconsider the exclusion of Onward Technologies Limited (OTL) as a comparable in the transfer pricing study. Detailed analysis and conclusion.

Delhi High Court Upholds Exclusion of Comparables in Transfer Pricing Case

October 31, 2023 600 Views 0 comment Print

Delhi High Court upheld the exclusion of comparables due to functional dissimilarity and significant turnover differences. Analysis of the PCIT vs. Qualcomm India Pvt Ltd case.

ITAT Deletes Penalty: Failure to file Form No. 3CEB due to CA’s Opinion

October 25, 2023 555 Views 1 comment Print

The Income Tax Appellate Tribunal (ITAT) in Pune deleted the penalty in the Jyoti Paper Udyog Ltd Vs. ACIT case due to non-production of Form No. 3CEB under Section 92E.

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