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...
Govt notifies extend due dates of Tax Audit/ITR/VSV Scheme vide Notification No. 93/2020-Income Tax dated 31st December, 2020 MINISTRY OF FINANCE (Department of Revenue) (CENTRAL BOARD OF DIRECT TAXES) Notification No. 93/2020-Income Tax New Delhi, the 31st December, 2020 S.O. 4805(E).—In exercise of the powers conferred by sub-section (1) of section 3 of the Taxation […]
In view of the continued challenges faced by taxpayers in meeting statutory compliances due to outbreak of COVID-19, the Govt further extends the dates for various compliances. Due date for filing ITR (Non tax audit) extended till 10/01/2021. Due date for filing Tax Audit and TP Audit Report extended till 15/01/2021. Due date for filing […]
Gujarat Federation of Tax Consultants Vs Union of India (Gujarat High Court) Gujarat High Court heard petition for extension of due dates in TAR and ITR for A Y 2020-21 on today. Court issued notice and fix next hearing on tomorrow. FULL TEXT OF THE HIGH COURT ORDER/JUDGEMENT Heard Mr. S. N. Soparkar, learned Senior […]
A. P. Tax Bar Association, Vijayawada has made a representation to Smt. Nirmala Sitaraman, Hon’ble Finance Minister and requested her for extending the time limit for filing GSTR 9 and 9C returns as also the Income Tax returns for the assessment years 2020-21 which would be beneficial to both individuals, firms and companies and also […]
Gimpex Pvt. Ltd. Vs ACIT (ITAT Chennai) There is no dispute with regard to the fact that receivables is included under the definition of international transactions by amending section 92B by the Finance Act, 2012 w.e.f. 01.04.2002. Therefore, we are of the considered view that there is no merit in the arguments advanced by the […]
ICAI has sent a Humble reminder to FM to for immediate consideration of their request(s) for extension of various due dates under Income-tax Act, 1961 especially Tax Audit Reports and related returns and Income Tax Return Forms for AY 2020-21. ICAI has also made an representation earlier on 13th December 2020. Full text of the […]
BJP Economic Cell, Rajasthan has requested Hon’ble Union Finance Mister to extend due dates of ITR for person (Non-Audit) (FY 2019-20), Tax Audit Reports (FY 2019-20), ITR for other persons (FY 2019-20), GST Annual Return GSTR9/9C/4 (FY 2018-19), GST Annual Return GSTR9/9C/4 (FY 2019-20), Vivad Se Vishwas Scheme, 2020, Companies Fresh Start Scheme. 2020 and […]
Hyderabad Chartered Accountants’ Society has requested 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. Full text of their representation to finance minister is as follows:- Hyderabad Chartered Accountants’ […]
Over the past few years issue of Advertisement, Marketing and Promotion (‘AMP’) expenses has become very prominent in Transfer Pricing Assessments in India, wherein Indian subsidiaries which are engaged in business activities using brand name of global multi-national enterprises (‘MNEs’). Indian Revenue Authorities (IRA) argues that AMP expenses involving brand promotion service by the taxpayer […]
All Odisha Tax Advocates Association made a Request for extension of due date for filing Tax Audit Reports (TARs), Income Tax Return (ITR) for the AY-2020-2021, statement under Vivad Se Vishwas Act, Audit and Annual Return (GSTR9, GSTR 9A, GSTR 9C) under the GST Act. Full Text of their representation is as follows:- ALL ODISHA […]
