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...
The Tribunal ruled that inclusion of giant companies distorted arm’s length results for a small captive service provider. High-turnover companies were excluded to ensure meaningful comparability.
The Tribunal held that mere facilitation of third-party payments to an associated enterprise does not constitute a service. As no value addition was involved, applying a markup on reimbursements was found unsustainable.
The Delhi High Court upheld exclusion of multiple comparables after finding them functionally different from a low-risk investment advisory service provider. It held that such findings were factual and did not raise any substantial question of law.
The Tribunal ruled that high-turnover IT companies cannot be benchmarked against smaller captive service providers. Proper FAR analysis is essential to determine arm’s length price under TNMM.
Tribunal held that a company engaged in diversified IT consultancy and transformation services cannot be compared with a routine software development service provider
The Tribunal held that advances linked to regular business dealings such as sale of timeshare weeks cannot be taxed as deemed dividend, reaffirming that commercial transactions fall outside section 2(22)(e)
The ruling set aside a large AMP adjustment after finding that commission paid to distributors could not be recharacterized as marketing expenditure. Consistency with prior years played a decisive role in deleting the adjustment.
The issue was whether the Assessing Officer could alter income despite a valid APA and modified return. The Court held that without an adverse TPO audit or APA cancellation, reassessment adjustments were without jurisdiction.
The Delhi High Court rejected the Revenue’s transfer pricing appeals, holding that no substantial question of law arose. The ruling followed earlier decisions on identical issues for prior years.
ITAT held that arm’s length price for electricity supplied to related entities must be benchmarked against the gross tariff charged by the State Electricity Authority. Excluding mandatory charges distorts comparability and is impermissible.
