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 : The Tribunal held that the Indian entity was only a distributor and not a technology or content owner. It rejected the Revenue’s...
Income Tax : This explains the new block assessment mechanism allowing ALP to apply across multiple years. It emphasizes reduced disputes and s...
Income Tax : The issue concerns replacement of Form 3CEB with a new reporting framework. The reform mandates structured reporting with enhanced...
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 : The issue was whether high-turnover companies can be compared with a smaller software service provider. The Tribunal held that com...
Income Tax : The Tribunal held that transfer pricing adjustment cannot survive without a final assessment order post-DRP directions. Repeating ...
Income Tax : The Tribunal held that subscription to preference shares cannot be re-characterized as loans in absence of evidence showing sham t...
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...
Income Tax : The Court held that Tribunal remand is not a fresh reference under transfer pricing law. Hence, limitation expired earlier, entitl...
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...
It is open to the parties in Transfer Pricing cases to take a stand contrary to their TP study, if they contend that the stand taken in the TP study is contrary to facts or was erroneous. Such a claim cannot be disregarded only on the basis that it is contrary to Assessee’s own stand in the TP study.
Nike India Pvt Ltd vs DCIT (ITAT Bangalore) The AO noticed that the assessee has claimed deduction for ‘Provision for sales returns’. When enquired, the assessee submitted that it creates a provision for anticipated sales returns based on a percentage of the sales made each month. It was further submitted that the provision is created […]
Bharti Airtel Services Ltd. Vs DCIT (ITAT Delhi) In the present case the service agreement clearly says that the amount of payment is to be made by the associated enterprises to the assessee within 15 days. Such payment was not made within that period but beyond that. The learned assessing officer held that the amount […]
Tax Bar Association, Jodhpur has made a representation to Smt. Nirmala Sitharaman, Hon’ble Union Minister of Finance & Corporate Affairs & Request for Extension of due date for filing of Tax Audit reports, Transfer Pricing Audits and Income-tax returns – AY 2020-21 till 31St March 2021. Text of the representation is as follows:- Dated: 10/10/2020 […]
Section 44AB of the Income-tax Act, 1961 contains the provisions for the tax audit of an entity. As per these provisions, Tax audit will be conducted by a practicing chartered accountant who ensures the taxpayer have maintained proper books of account and complied with the provisions of the Income-tax Act. In view of the challenges […]
Chamber of Tax Consultants has made a representation to Smt. Nirmala Sitharaman, Hon’ble Finance Minister, requesting Extension of Due Dates for filing Tax Audit, Transfer Pricing Audit and Income Tax Return for Assessment Year 2020-21. Text of the representation is as follows:- Date: 7th October, 2020 To, Smt. Nirmala Sitharaman, Hon’ble Finance Minister, Ministry of […]
Benchmarking of cost to cost reimbursement of expenses was not within the jurisdiction of the TPO while computing the arm’s length price of the international transaction u/s 92CA of the Act.
Approach of the learned transfer pricing officer of determining ALP of international transaction of incurring of higher AMP expenditure cannot be benchmarked either on Bright line test bases or on transactional net margin method unless first it is established that there existed an international transaction. Accordingly all the grounds of the appeal of the assessee relating to the transfer pricing adjustment are allowed.
The issue under consideration is whether the writ petition filed against the order of DRP rather than first go for appeal before tribunal is justified in law?
EMC Software & Services India Pvt. Ltd. Vs. JCIT (ITAT Banglore) The assessee seeks inclusion of T2T2 India Ltd. The Ld. A.R. submitted that this company is functionally comparable company. The TPO/DRP has rejected the same only for the reason that the detail of Related Party Transactions (RPT) was not disclosed in the Annual Report. […]
