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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 327 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 639 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 981 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 4500 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


Extend Tax/TP Audit & ITR Due dates for AY 2020-21

December 24, 2020 10296 Views 1 comment Print

Sales Tax Bar Association, Delhi has made a request to FM   for extension of due dates for Tax Audit, Transfer Pricing Audit, Statutory Audit and Income Tax Returns Filing for the Assessment Year 2020-21. Relevant Text of the Representation is as follows:- SALES TAX BAR ASSOCIATION December 21, 2020 To, Smt Nirmala Sitharaman, Hon’ble […]

Tax Professionals urge extension of dates for ITR as well as VSV & AGM

December 23, 2020 1140 Views 0 comment Print

Direct Taxes Professionals Association (DTPA), Kolkata has urged Smt. Nirmala Sitharaman, Finance Minister for extension of date of furnishing of Tax Audit Report under section 44AB to 28th February, 2021 and the due date of filing ITRs of Asst Year 2020-21 in audit cases to 31st March, 2021. CA NK Goyal, President of DTPA pointed […]

Open letter for extension of Due dates under Income Tax and GST

December 23, 2020 33378 Views 4 comments Print

A letter is doing round on Social Media which is written on behalf of  All Professionals, Tax Payers and Stakeholders in which A very humble prayer for further relaxation of provisions of section 139(1) and section 44AB of the Income Tax Act, 1961 by granting extension of due date and specified date respectively etc. from […]

Extend due dates for Tax Audit & Income Tax Return filing for AY 2020-21

December 23, 2020 65520 Views 28 comments Print

Luminaires Accessories Components Manufacturers Association has requested FM to extend the due dates for Tax Audit and Income Tax Return filing to March 31, 2021 for the Assessment Year 2020-21 .  Relevant Text of their representation is as follows:- To, Smt. Nirmala Sitharaman Hon’ble Finance Minister, Ministry of Finance, North Block, New Delhi 110 001. […]

Extend Income Tax & GST Return & Audit due dates

December 23, 2020 4827 Views 1 comment Print

Chandigarh Chartered Accountants Taxation Association has made a request for extension of various due dates under Income-tax Act, 1961 for AY 2020- 21 and for filing the Annual Reconciliation Statement (GSTR9C) along with the annual return (GSTR9) for financial years 2018-2019 & 2019-2020. Full text of their Representation to Smt. Nirmala Sitharaman, The Hon’ble Finance […]

Extend Time for filing ITR & Audit Report for A.Y 2020-21

December 23, 2020 22971 Views 4 comments Print

Income Tax Bar Association, Lucknow has requested Union Finance Minister to extend the due dates for tax audit and transfer pricing audit to 31st March 2021 and the Income Tax return filing also to 31st March, 2021 at the earliest. Relevant Text of the representation is as follows:- INCOME TAX BAR ASSOCIATION LUCKNOW (REGISTERED UNDER […]

Extend due of ITR, GSTR 9, 9A & 9C for FY 2018-19 & 2019-20

December 22, 2020 28599 Views 7 comments Print

Tax Consultant & Practitioners Association of Kerala has made a request for the extension of due date of ITR for AY 2020-21 and GSTR 9, 9A & 9C for FY 2018-19 & 2019-20. They requested for extension of due date of Filing Income Tax Return,  GSTR9, 9A & 9C for the FY 2018-19 & 2019-20 […]

Extend due date of ITR/Tax Audit/GSTR-9/GSTR-9C

December 21, 2020 35253 Views 2 comments Print

Tax Bar Association (Regd), Allahabad has made a representation to FM with reference to Extension of Due dates of Income Tax Audit, Income Tax Return Filing, GSTR 9 and GSTR 9C. Some of the request made are as follows:- 1. Extend due date of GSTR-9 and GSTR-9C for Financial Year 2018-19 to 28/02/2021. 2. Extend […]

Extend Tax Audit/ITR due dates for AY 2020-21

December 21, 2020 108105 Views 35 comments Print

Tax Bar Association, Guwahati has made a Request for Extension of Due Dates for furnishing of Tax Audit Report & Income Tax Return for Assessment Year 2020-21 to Smt. Nirmala Sitharaman, Hon. Finance Minister of India.  Request is been made to extend the due dates of furnishing of Tax Audit Report U/s 44AB to 28th […]

Extend due of GSTR-9, GSTR-9A & GSTR-9C

December 21, 2020 19533 Views 1 comment Print

Association of Tax payers & Professional, Agra has requested to Finance Minister to extend due dates of Income Tax Return Filing for Financial year 2018-19 to 31st December 2020, It further requested that due date of filing GSTR-9 be extended to 31st January 2021 and due date of filing GSTR-9A & GSTR-9C be extended to […]

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