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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 1140 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 1113 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 6489 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 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

TP Adjustment Quashed as Benefit Test Cannot Justify NIL ALP After Service Receipt Is Established

Income Tax : ITAT Ahmedabad held that transfer pricing authorities cannot assign a NIL arm’s length price when the assessee has demonstrated ...

June 8, 2026 99 Views 0 comment Print

ITAT Remands TP Adjustment Issue as RPT Filter Was Not Properly Verified

Income Tax : The Hyderabad ITAT found contradictions in the TPO’s reasoning for excluding a comparable company due to alleged lack of RPT dat...

June 5, 2026 111 Views 0 comment Print

Pune ITAT Deletes ₹5.67 Crore TP Adjustment; TPO Cannot Cherry-Pick One Transaction While Accepting TNMM for Others

Income Tax : Pune ITAT held that once TNMM is accepted for a taxpayer’s aggregated international transactions, the TPO cannot isolate a singl...

June 3, 2026 210 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 Tax Audit/ITR due dates for AY 2020-21

December 21, 2020 108426 Views 35 comments Print

Tax Bar Association, Guwahati has made a Request for Extension of Due Dates for furnishing of Tax Audit Report & Income Tax Return for Assessment Year 2020-21 to Smt. Nirmala Sitharaman, Hon. Finance Minister of India.  Request is been made to extend the due dates of furnishing of Tax Audit Report U/s 44AB to 28th […]

Extend due of GSTR-9, GSTR-9A & GSTR-9C

December 21, 2020 19593 Views 1 comment Print

Association of Tax payers & Professional, Agra has requested to Finance Minister to extend due dates of Income Tax Return Filing for Financial year 2018-19 to 31st December 2020, It further requested that due date of filing GSTR-9 be extended to 31st January 2021 and due date of filing GSTR-9A & GSTR-9C be extended to […]

Representation for Extension of time for Tax Audit & Return

December 21, 2020 29010 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 253707 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 67758 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 69474 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 32703 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 40338 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 2094 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 1782 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 […]

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