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Transfer Pricing

Latest Articles


India Transfer Pricing- Due Dates for Compliance for Tax Year 2026-27

Income Tax : The update outlines revised compliance forms, timelines, and penalties under the new rules. It highlights a structured transition ...

April 17, 2026 204 Views 0 comment Print

Transfer Pricing MAM Selection: Germany–India Subsidiary Case (TNMM Approach)

Corporate Law : The issue was identifying the correct transfer pricing method for intercompany transactions. The conclusion holds that TNMM is app...

April 14, 2026 135 Views 0 comment Print

Netflix India Wins ₹444 Crore Transfer Pricing Fight

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...

April 13, 2026 324 Views 0 comment Print

Transfer Pricing under Income Tax Act: ALP, AEs & Compliance Framework

Income Tax : This explains the new block assessment mechanism allowing ALP to apply across multiple years. It emphasizes reduced disputes and s...

April 9, 2026 636 Views 0 comment Print

Form No. 48: Transfer Pricing Certification under Income-tax Act, 2025

Income Tax : The issue concerns replacement of Form 3CEB with a new reporting framework. The reform mandates structured reporting with enhanced...

April 6, 2026 978 Views 0 comment Print


Latest News


Record 219 APAs Signed Due to Rising Need for Transfer Pricing Certainty

Income Tax : CBDT signed a record number of APAs to provide clarity on transfer pricing and reduce disputes. The framework ensures advance dete...

April 1, 2026 228 Views 0 comment Print

KSCAA Seeks Parity in ITR Due Date Extension for Transfer Pricing Assessees

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...

November 3, 2025 480 Views 0 comment Print

CA Association Seeks Extension for ITR, Tax and TP Audit Dates

CA, CS, CMA : Chartered Accountants Association, Ahmedabad requests extension of ITR and audit due dates for AY 2025-26 citing compressed timeli...

September 10, 2025 8139 Views 1 comment Print

Tolerance Range for Transfer Pricing Notified for AY 2024-25

Income Tax : CBDT sets transfer pricing tolerance range at 1% for wholesale trading and 3% for other transactions for AY 2024-25, providing cla...

October 30, 2024 2199 Views 0 comment Print

Budget 2024: TPO can evaluate SDTs not reported by taxpayers

Income Tax : From April 2025, TPOs can determine ALP for SDTs not initially referred or reported. This ensures accurate adjustments and complia...

July 26, 2024 1044 Views 0 comment Print


Latest Judiciary


Companies with significantly higher turnover are not comparable: ITAT Bangalore

Income Tax : The issue was whether high-turnover companies can be compared with a smaller software service provider. The Tribunal held that com...

April 2, 2026 315 Views 0 comment Print

Missed DRP timeline kills TP addition; ₹288 Cr share capital upheld

Income Tax : The Tribunal held that transfer pricing adjustment cannot survive without a final assessment order post-DRP directions. Repeating ...

March 27, 2026 426 Views 0 comment Print

ITAT Mumbai Rejects TP Adjustment as Preference Shares Cannot Be Treated as Loans Without Evidence

Income Tax : The Tribunal held that subscription to preference shares cannot be re-characterized as loans in absence of evidence showing sham t...

March 24, 2026 411 Views 0 comment Print

ITAT Allows 10% Safe Harbour on DVO Valuation Due to Estimation Nature of Property Values

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...

March 21, 2026 411 Views 0 comment Print

United Spirits Case: Remand in TP Case Does Not Extend Section 153 Limitation

Income Tax : The Court held that Tribunal remand is not a fresh reference under transfer pricing law. Hence, limitation expired earlier, entitl...

March 21, 2026 267 Views 0 comment Print


Latest Notifications


Income Tax ALP Tolerance Range for AY 2025-26 Notified

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...

November 6, 2025 4779 Views 0 comment Print

Amendment of Safe Harbour Rules for AY 2025-26 under Section 92CB

Income Tax : CBDT notifies Income Tax (Sixth Amendment) Rules, 2025, introducing safe harbour rules for assessment year 2025-26. Full details o...

March 25, 2025 4596 Views 0 comment Print

Tolerance Range for Arm’s Length Price in FY 2024-25

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...

October 18, 2024 3168 Views 0 comment Print

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 4497 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 12663 Views 0 comment Print


Uttarakhand HC directs CBDT to consider representation on due date extension

January 15, 2021 24924 Views 6 comments Print

The Dehradun Chartered Accountants Society Vs. Union of India (High Court of Uttarakhand at Nainital) High Court held that Admittedly, the country continues to suffer and to reel under the COVID-19 pandemic. A large number of assesses still find it difficult to even meet their Chartered Accountants and to file their Income Tax Audit Reports […]

Extension of due date for filing TAR/ITR – HC declined to interfere

January 14, 2021 24873 Views 9 comments Print

High Court (HC) declined to interfere in the matter of extension of the due date for filing Tax Audit Report (TAR) and Income Tax Return (ITR) The Hon’ble Gujarat High Court in All Gujarat Federation of Tax Consultants v. Union of India [R/Special Civil Application No.  13653 and 660 of 2021, dated January 13, 2021] […]

All India Protest Call against GST/Income Tax Issues by WMTPA

January 13, 2021 99144 Views 85 comments Print

Government is neither listening to representations submitted by various associations, nor listening to court direction in true spirit. In Covid 19 pandemic, all professionals and Trade, ignoring life and death risk, ensured that, India will stand again, paid taxes in lakh crores but it seems government doesn’t recognize us.

Gujarat HC rejects TAR/ITR due date date extension writ applications

January 13, 2021 17454 Views 0 comment Print

At this stage, we may only observe that the CBDT may consider issuing an appropriate circular taking a lenient view as regards the consequences of late filing of the Tax Audit Reports as provided under Section 271B of the Act. We leave it to the better discretion of the CBDT in this regard.

Group service fees paid to AEs: ITAT restore the matter to AO / TPO

January 12, 2021 1215 Views 0 comment Print

Disa India Limited Vs ITO (ITAT Bangalore) The Tribunal in assessee’s own case for assessment year 2012-2013 (supra) had directed to do afresh transfer pricing analysis and determine the ALP of international transactions with regard to group service fees paid by the assessee to its AEs. In view of the Tribunal order in assessee’s own […]

Extend due dates of GST, Income Tax & ROC Compliances

January 10, 2021 49323 Views 14 comments Print

All India Joint Representation Committee for GST have filed representation by way of join petition of 24 GST and Trade Associations and 5226 signatories to the signature campaign considering short extension granted in connection with GSTR 9 & 9C for FY 1819 & FY 1920 , Income Tax Returns, Tax Audit and Transfer Pricing Reports […]

Take appropriate decision on extension of due date of filing ITR & TAR by 12.01.2021: Gujarat HC to CBDT

January 10, 2021 4473 Views 2 comments Print

The Hon’ble High Court, Gujarat in the All Gujarat Federation of Tax Consultants v. Union of India [R/Special Civil Application No. 13653 of 2020 dated January 8, 2021] directed CBDT to take an appropriate decision for extension of the due date of filing income tax return (ITR) and Tax audit report (TAR) by January 12, […]

What if Due Date for filing ROI on 10th January 2021 falls on a Sunday?

January 10, 2021 30939 Views 1 comment Print

10th January 2021, the last date of filing of ROI u/s 139(1), falls on Sunday. In such a case what should be the due date ROI u/s 139(1)? 10th January 2021 or 11th January 2021? Opinions varies. An analysis of the provisions affecting the Due Date may perhaps clarify the issue. General Clauses Act 1977: […]

Extend due dates of TAR/ITRs/VSV Scheme for AY 2020-21

January 9, 2021 21657 Views 4 comments Print

Calcutta Citizens’ Initiative, Representation on Extension of due dates of Vivad Se Vishwas Scheme and also for extension of date for TAR and ITRs for asst year 2020-21. Calcutta Citizens’ Initiative 3, Ho Chi Minh Sarani, Ground Floor, Kolkata 700001 Ph – 033-2466-1000 Email: calcuttacitizens@gmail.com URGENT Ref. CII/Rep/2021/01 Dated: 9th January 2021 Shri P.C. Mody, Chairman, […]

Further extend Income Tax Return & Audit due dates

January 9, 2021 83349 Views 4 comments Print

Direct Taxes Professionals’ Association, Kolkata has requested FM for further extension of various due dates under Income-tax Act, 1961 especially Income Tax Return Forms for AY 2020­- 21, Tax Audit Reports and other related Returns for AY 2020­- 21. Text of their representation is as follows:- DIRECT TAXES PROFESSIONALS’ ASSOCIATION Income Tax Building, 3, Govt. […]

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