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Transfer Pricing

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Safe Harbour Rules under New Income Tax Act, 2025 & Rules, 2026- Part III

Income Tax : This article explains how Safe Harbour Rules under the Income-tax Act, 2025 interact with APAs, MAP provisions, and transfer prici...

May 7, 2026 1143 Views 0 comment Print

Safe Harbour Rules under New Income Tax Act, 2025 & Rules, 2026- Part II

Income Tax : The framework outlines mandatory disclosures and timelines for opting into safe harbour. Key takeaway: strict compliance is essent...

May 1, 2026 1116 Views 0 comment Print

Safe Harbour Rules under New Income Tax Act, 2025 & Rules, 2026: Part I

Income Tax : The article explains how safe harbour rules simplify transfer pricing compliance. It highlights that eligible transactions are acc...

April 28, 2026 6531 Views 0 comment Print

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 1374 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 342 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 402 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 543 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 8184 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 2403 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 1104 Views 0 comment Print


Latest Judiciary


ITAT Delhi Remands Transfer Pricing Case Due to Alleged Double Addition of TP Adjustments

Income Tax : The Tribunal restored the matter to the Assessing Officer after finding that transfer pricing adjustments may have been added twic...

June 9, 2026 48 Views 0 comment Print

Channel Owner Companies not Comparable Due to Functional Differences: ITAT Delhi

Income Tax : ITAT Delhi held that television channel and content owner companies could not be compared with a content distribution business. Th...

June 9, 2026 63 Views 0 comment Print

Distribution Fee for Channel Distribution Not Royalty: ITAT Mumbai

Income Tax : ITAT Mumbai held that distribution fees paid to associated enterprises could not be treated as royalty. The Tribunal followed earl...

June 9, 2026 72 Views 0 comment Print

ITAT Deletes Management Fee TP Adjustment as Issue Was Already Decided in Earlier Years

Income Tax : ITAT Mumbai deleted the transfer pricing adjustment on management fees after finding that identical issues in the assessee’s own...

June 8, 2026 117 Views 0 comment Print

No TP Adjustment Allowed if Foreign LLC Income Was Already Taxed in India: ITAT Delhi

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...

June 8, 2026 153 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 5121 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 4971 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 3357 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 4650 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 12819 Views 0 comment Print


Extend due dates of GST, Income Tax & ROC Compliances

January 10, 2021 49464 Views 14 comments Print

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 […]

Take appropriate decision on extension of due date of filing ITR & TAR by 12.01.2021: Gujarat HC to CBDT

January 10, 2021 4515 Views 2 comments Print

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, […]

What if Due Date for filing ROI on 10th January 2021 falls on a Sunday?

January 10, 2021 31212 Views 1 comment Print

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: […]

Extend due dates of TAR/ITRs/VSV Scheme for AY 2020-21

January 9, 2021 21720 Views 4 comments Print

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, […]

Further extend Income Tax Return & Audit due dates

January 9, 2021 83412 Views 4 comments Print

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. […]

Consider extension of Income Tax Due dates: Gujarat HC to UOI

January 8, 2021 26004 Views 0 comment Print

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 request for further extension of Income-tax due dates

January 8, 2021 19503 Views 2 comments Print

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 for further extension of TAR/ITR due dates

January 8, 2021 58830 Views 14 comments Print

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, […]

CA Association Criticised Action & Policies of FMO after insufficient due date extension

January 8, 2021 46956 Views 11 comments Print

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 […]

Extend Income-tax due dates with humane approach

January 5, 2021 54306 Views 38 comments Print

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 […]

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