Income Tax : Section 144C of IT Act, 1961 was brought through Finance Act, 2009 & introduced for orderly assessment with respect to the interna...
Income Tax : Understand penalties for under-reporting and misreporting of income in transfer pricing adjustments, as per the Income Tax Act 196...
Income Tax : Chapter X of the Income Tax Act applies solely to transactions with Associated Enterprises (AEs), excluding non-AE transactions fr...
Income Tax : Revenue authorities lack jurisdiction to question the business decisions or commercial wisdom of taxpayers in transfer pricing cas...
Income Tax : The ITAT remands BorgWarner's case on TSS, BSS, and royalty benchmarking to TPO for re-determination, questioning the segregation ...
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 : What is the procedure to approve Form 3CEB? Form uploaded by CA shall be available under For your action tab in Taxpayer’s Workl...
Income Tax : ICAI Releases Exposure Draft Guidance Note On Report Under Section 92E Of Income-Tax Act, 1961 (Transfer Pricing) Based on the la...
Income Tax : Association for Corporate Advisers and Executives (ACAE) made a Request for Extension of Due Dates for filing Tax Audit and Transf...
Income Tax : Delhi High Court upheld the ITAT’s decision, concluding that the comparability analysis must focus on functional similarity rath...
Income Tax : Delhi High Court remands Alcatel Lucent's transfer pricing case to ITAT, questioning selection of comparables in ALP determination...
Income Tax : Delhi High Court judgment on Cadence Design's appeal against the ITAT order regarding transfer pricing comparables. Key findings o...
Income Tax : ITAT Delhi remands JCB India Ltd.'s ₹166.09 crore TP adjustment for non-UK royalty payments to TPO for fresh consideration....
Income Tax : Delhi HC ruling clarifies that KPO service providers aren't comparable to ITES providers for benchmarking international transactio...
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...
Income Tax : Notification No. 46/2023-Income-Tax Dated: 26th June, 2023 regarding deemed arm's length price for assessment year 2023-2024. Le...
Income Tax : In exercise of the powers conferred by the third proviso to sub-section (2) of section 92C of the Income-tax Act, 1961 (43 of 1961...
Maximize transfer pricing accuracy with our guide on Comparability and Functional Analysis, aligning transactions with the arm’s length principle for compliance and strategic insights.
Actions 8-10 of the Base Erosion and Profit Shifting (BEPS) agenda aim to address misapplications of international transfer pricing rules. These misapplications result in profit allocations not aligned with the economic activities generating them.
Explore the comprehensive requirements of Action 13 of the BEPS Action Plan on transfer pricing documentation, including local file, master file, and country-by-country reporting. Learn about implementation thresholds and India’s incorporation of these standards.
ITAT Mumbai rules that comparables cannot be excluded if their financial data can be reasonably extrapolated, in Syngenta Services Private Limited’s case.
Explore the evolution of harmful tax practices from the OECD’s 1998 report to the BEPS Action 5 approach, focusing on transparency, substantial activity requirements, and the eradication of harmful regimes.
ITAT Mumbai rules against penalty under Sec 271G for a diamond trader’s failure to provide segmental information, emphasizing substantial compliance.
ITAT Delhi resolves Boeing India’s transfer pricing dispute, clearing an INR 21,52,899 adjustment tied to operational inactivity and a merger with BCIL.
In the case of American Express Services India Ltd. Vs DCIT, Delhi ITAT remits the matter for correct market segment selection, following earlier order. Full text of the ITAT Delhi order included.
Explore the Cost Plus Method for transfer pricing. Learn its application, methodology, and key considerations. Navigate complexities with practical examples.
Explore the intricacies of Resale Price Method (RPM) in transfer pricing. Understand its components, implementation steps, and real-world applications. Dive into case examples highlighting strengths, weaknesses, and considerations for reliable comparisons
