Income Tax : Learn about the amendments to Section 92CA concerning references to the Transfer Pricing Officer for determining arm's length pric...
Income Tax : New transfer pricing rules allow arm’s length price (ALP) determinations to apply for two consecutive years, reducing compliance...
Income Tax : Finance Bill 2025 allows multi-year Arm’s Length Price determination for similar transactions, reducing repetitive proceedings i...
Finance : The Finance Bill 2025 proposes multi-year ALP determination to reduce compliance burdens in transfer pricing. Learn about its fram...
Income Tax : Karnataka HC ruled that omission of Section 92BA(i) invalidates its application to domestic transactions, limiting transfer pricin...
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Income Tax : ICAI Releases Exposure Draft Guidance Note On Report Under Section 92E Of Income-Tax Act, 1961 (Transfer Pricing) Based on the la...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 : It was held that transactions and FAR of assessee were similar to AY 2021-22 and as per the records brought to our notice, there...
Income Tax : Respondent/assessee is a Irish company. It accordingly claimed benefits of the India-Ireland DTAA. ADIR is a wholly owned subsidia...
Income Tax : In the matter above-mentioned ITAT partly allowed the appeal filed by the assessee by remanded it back to file of TPO after consid...
Corporate Law : Delhi HC rules that SEB rates, not IEX rates, determine the market price of electricity in transfer pricing cases, dismissing Reve...
Income Tax : ITAT Delhi clarifies tax treatment for Motricity India: No levy on notional income or closure costs. Insights on Transfer Pricing ...
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...
Income Tax Department designates Income tax Authority before whom particulars of parent entity and alternate reporting entity to file Country-by-Country Report would be notified
Kaybee Pvt Ltd Vs ITO (ITAT Mumbai) Section 92A(2) governs the operation of Section 92A(1) by controlling the definition of participation in management or capital or control by one of the enterprise in the other enterprise. If a form of participation in management, capital or control is not recognized by Section 92A(2), even if it […]
The assessee is one of the group companies of China based TIENS Group of Companies. The business of the assessee, is Trading/Distribution of Food Supplements and Health Care Equipments. The products dealt with by the Company are basically products manufactured at China or other places by Group concerns. Another Group Entity Tianjin Tianshi Biological Development Company Limited, incorporated at China has established a Foreign Branch Office in India.
Celltick Technologies Ltd Vs DCIT (ITAT Mumbai) If the arms length principle is satisfied qua the relevant transaction between the assessee and its Indian subsidiary, no further profits can be attributed to the assessee in India even if it was to be held that the latter had a PE in India e find that the […]
Transfer Pricing Compliance Chart for Financial Year 2019-20 which includes Transfer Pricing Audit, Transfer Pricing Study- Documentation, Return of Income (Having applicability of Transfer Pricing Provisions), Master File, Intimation by a designated Constituent Entity, Intimation by Designated Constituent Entity and CbCR. Activity Section / Rule Form No. Old Deadline New Deadline Remarks Transfer Pricing Audit […]
PCIT Vs. Gulbrandsen Chemicals Pvt. Ltd. (Gujarat High Court) The Tribunal has taken into consideration the voluminous documentary evidence on record for the purpose of coming to the conclusion of adoption of TNMM by the assessee as the Most Appropriate Method of arriving at ALP. The Delhi High Court in the case of Make My […]
The Hon’ble Finance Minister, Ms. Nirmala Sitharaman, presented the Union Budget on 1 February 2020, introducing measures aimed at, inter-alia, reducing litigation, improving effectiveness of tax administration, providing tax certainty and simplifying compliance with the overall objective of enhancing the ease of doing business in India. This article focuses on key proposals relating to Indian […]
ITATheld that the ad hoc determination of ALP de-hors Section 92C of the Act cannot be sustained, rendering the entire transfer pricing adjustment unsustainable in law.
Key Highlights of Transfer Pricing Proposal in Union Budget 2020-21: > As per amended provisions, Form 3CEB filing date is 31st October 2020 for FY 2019-20. > Dispute Resolution Panel forum is now not limited to Transfer Pricing disputes only but also allowed to non residents for all disputes. > Provisions of interest limitation (Section […]
It can be fairly concluded from the above judicial pronouncements that the receivable mentioned in the Explanation to Sec.92B can be taken up for transfer pricing scrutiny only when it is a standalone activity or a demonstrated approach is adopted by the assessee to use Accounts Receivable to have free working capital funding.
