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...
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, […]
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: […]
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, […]
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. […]
All Gujarat Federation of Tax Consultants Vs Union of India (Gujarat High Court) High Court held that respondent No.1 – Union of India, Ministry of Finance should immediately look into the issue, more particularly, the representation dated 12th October 2020 at Annexure : I of the paper book (page 108) and take an appropriate decision […]
AIFTP Representation 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
ICAI request FM to consider further extension(s) of various due dates under Income-tax Act, 1961 especially Tax Audit Reports (TAR) and related returns and Income Tax Return (ITR) Forms for AY 2020-21. text of their representation is as follows:- ICAI/DTC/2020-21/Rep-31 To Chairman, Central Board of Direct Taxes, Ministry of Finance, Government of India, North Block, […]
Chartered Accountants Association, Surat has written a letter to FM and criticized Finance Minister Office (FMO) for its Poor Actions and Policies. As per the letter Actions of FMO ultra-vires the Citizen’s Charter, Deteriorated working standards and health of the stakeholders, FMO failed in recognition of efforts put by the tax professionals, Ignoring communication with […]
The Chamber of Tax Consultants has made a representation TO FM & CBDT and requested for Extension of various due dates for compliances under the Income-tax Act, 1961 and also Requested FM & CBDT to adopt humane approach in handling the extension of due dates in the times of the pandemic. Full text of their […]
PCI Limited Vs ACIT (ITAT Delhi) The Assessing Officer made the addition of Rs.73,69,830/-qua Transfer Pricing Adjustment on account of providing corporate guarantee by the Assessee to its overseas associated enterprises companies, namely, PCI Asia Pacific Pvt. Ltd. and PCI Middle East FZE by treating the interest rate of 1.3% based on average fees charged […]
