Income Tax : This article explains how Safe Harbour Rules under the Income-tax Act, 2025 interact with APAs, MAP provisions, and transfer prici...
Income Tax : The framework outlines mandatory disclosures and timelines for opting into safe harbour. Key takeaway: strict compliance is essent...
Income Tax : The article explains how safe harbour rules simplify transfer pricing compliance. It highlights that eligible transactions are acc...
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 : 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 : ITAT Delhi held that television channel and content owner companies could not be compared with a content distribution business. Th...
Income Tax : ITAT Mumbai held that distribution fees paid to associated enterprises could not be treated as royalty. The Tribunal followed earl...
Income Tax : ITAT Mumbai deleted the transfer pricing adjustment on management fees after finding that identical issues in the assessee’s own...
Income Tax : The ITAT held that transfer pricing adjustment was not justified where the foreign LLC’s income was already offered to tax in In...
Income Tax : ITAT Ahmedabad held that transfer pricing authorities cannot assign a NIL arm’s length price when the assessee has demonstrated ...
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...
Lam Research (India) Pvt. Ltd. Vs DCIT (ITAT Bangalore) It was submitted that Working capital adjustment is made for the time value of money lost when credit time is given to the customers. The Assessee however does not bear any risk and has no working capital contingencies. The Assessee has not incurred any expenses for […]
ADIT Vs Asia Today Limited (ITAT Mumbai) It has not been the case of the revenue authorities at any stage that the remuneration paid to the Indian agent is not an arm’s length remuneration for the services rendered by the agents concerned, yet a prayer is now made that the matter should be sent back […]
Rayban Sun Optics India Ltd. Vs ACIT (ITAT Delhi) We are of the considered opinion that the ALP of an international transaction involving AMP expenses, the adjustment made by the TPO/DRP/AO is not sustainable in the eyes of law. At the same time, we cannot ignore the submission of the learned DR that the matter […]
PCIT Vs Novell Software Development (India) Pvt. Ltd. (Karnataka High Court) Facts: 1. Taxpayer, a captive software development and support service provider, is subsidiary of Novell Inc US. The taxpayer provided software development and support services to its US Associated Enterprise and adopted Transactional Net Margin Method. 2. The taxpayer was providing depreciation as per […]
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 […]
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] […]
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.
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.
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 […]
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 […]
