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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 354 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 141 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 357 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 687 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 1014 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 483 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 2205 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 321 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 414 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 273 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 4788 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 4614 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 3174 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


Representation for Extension of time for Tax Audit & Return

December 21, 2020 28899 Views 9 comments Print

The Uttar Pradesh Tax Bar Association has made a Representation for Extension of time for filing Income Tax Return and for Income Tax Audit and they requested for extension of due dates to 31.03.2021 from the existing due dates of 31.12.2020. Download Representation for Extension of time for Tax Audit & Return in PDF Format […]

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

December 21, 2020 253464 Views 86 comments Print

Emerging Businesses Chamber Of Commerce has made a representation to FM and Request for Extension of Due Dates for filing Tax Audit, Audit Reports under income Tax Act and ITR for Assessment Year 2020-21. Request was made in view of The Covid-19 Pandemic, Night Curfew and its effect on professional work, Ongoing Farmers Protest in […]

Extend Income Tax & GST Audit/Return/Compliance dates

December 20, 2020 67566 Views 19 comments Print

Vyyapaar Mandal Association, Nagore & All India MSME and Tax Practitioners Association (AIMTPA) has made a representation to FM for Extension of Due date of GST Annual Returns F.Y. 2018-19 and 2019-20, and Income Tax Return & Tax Audits for A.Y. 2020-21 and compliance of Notices. Relevant Text of their Representation is as follows:- Dated: […]

Extend Due Dates for Tax Audit and Income Tax Return Filing

December 19, 2020 69285 Views 14 comments Print

Chartered Accountants Association, Jalandhar has made a representation to the FM and requested for extension of Due Dates for Tax Audi and Income Tax Return Filing for the Assessment Year 2020-21. Full text of the representation is as follows:- Chartered Accountants Association (C R Building, Model Town Road, Jalandhar) For correspondence care:- CA. Ashwani Jindal, […]

Request for extension of due dates of Tax Audit Reports/ITR

December 19, 2020 32478 Views 19 comments Print

All India Federation of Tax Practitioners (CZ) has requested CBDT that due date of filing return of income u/s 139(1) for all the assesses be suitably extended, to 28.02.2021,from the current extended due date of 31.12.2020 for AY 2020-21. Simultaneously, the ‘specified date’ for filing tax audit reports be extended from 31.12.2020 to 28.02.2021 as […]

Extend Tax/TP Audit Report & ITR filing due date for AY 2020-21

December 18, 2020 40197 Views 5 comments Print

CA Social Affiliation (CASA) has requested FM to extend the due dates of furnishing of Tax Audit Report U/s 44AB and Transfer Pricing Audit Report U/s 92E to 28th February, 2021 and Income Tax Return due date to 31st March, 2021 for all type of assessee for Assessment Year 2020-21.  Full Text of the Representation […]

Consideration of Provision for bad & doubtful debts as operating expenses in computation of PLI

December 18, 2020 2037 Views 0 comment Print

ADP Private Ltd. Vs CIT (ITAT Hyderabad) With regard to the working capital adjustment, it is the case of the assessee that the provision of bad and doubtful debts should be considered as operating expenses while computing the PLI. He submitted that the transactions can be considered as a comparable only after making adjustments to eliminate […]

Functionally dissimilar comparable cannot be included

December 17, 2020 1767 Views 0 comment Print

Samsung India Electronics Pvt. Vs Addl. CIT (ITAT Delhi) OTS E-Solutions Pvt. Ltd.: From the perusal of the records it can be seen that OTS E-Solutions Pvt. Ltd. was held as not comparable in subsequent assessment year i.e. A.Y. 2014-15 by the Tribunal. The functional dissimilarity is apparent on record and there are no changes […]

Request to Extend Due dates under GST & Income Tax

December 15, 2020 28920 Views 7 comments Print

A Request for extension of various due dates under Income-tax Act, 1961 for AY 2020­-21 and for filing the Annual Reconciliation Statement (GSTR-9C) along with the annual return (GSTR-9) for financial years 2018-2019 & 2019-2020 is made by Bombay Chartered Accountants’ Society, Chartered Accountants Association (Ahmedabad), Chartered Accountants Association (Surat), Karnataka State Chartered Accountants Association […]

Extend due dates of Tax Audit Reports/ITR for A.Y. 2020-21

December 15, 2020 152262 Views 21 comments Print

AGFTC, ITBC and CAA has made a Request for further extension of due dates of furnishing Tax Audit Reports/ITR for A.Y. 2020-21 due to spike in Covid cases and consequential delay in notification/amendment of ITR forms/e-filing platform to Ms. Nirmala Sitharaman, Union Finance Minister of India. Text of the Representation is as follows:- To, Ms. […]

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