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...
Learn why regulators now require formal valuation of corporate guarantees to avoid tax, FEMA, and transfer pricing issues.
The ITAT held that depreciation cannot be disallowed when ownership, usage, and actual cost of assets are undisputed. Mere suspicion about the source of funds is insufficient to deny statutory depreciation.
The issue was whether interest on INR-denominated CCDs should be benchmarked using LIBOR or domestic rates. The Tribunal held that PLR applies, rendering the transfer pricing adjustment unsustainable.
The High Court dismissed the appeal after holding that the Tribunal’s findings on intra-group services raised no substantial question of law.
ITAT Bangalore allowed deduction of ₹55.4 crore ESOP expenses under section 37, holding it as employee compensation cost. ESOP costs may be deductible even if cross-charged from parent company.
The ITAT Pune held that splitting royalties for domestic vs export sales was impermissible, deleting the entire transfer pricing adjustment. The ruling reinforces that TNMM aggregation for manufacturing includes royalties as a single element.
The Tribunal held that once TNMM is accepted for a set of linked transactions, the TPO cannot separately benchmark Management Fees or treat their ALP as Nil. The adjustment was deleted as the fees were already included in the cost base used for arm’s length analysis.
The Tribunal upheld CIT(A)’s deletion of ₹2.81 crore transfer pricing adjustment, ruling that selected comparables were functionally and financially dissimilar. PSM was maintained as the Most Appropriate Method, ensuring fair benchmarking of international transactions.
Breaks down India’s transfer pricing framework, recent amendments, and judicial trends, highlighting how the arm’s-length principle is applied and what taxpayers must comply with.
Covers the Tribunal’s ruling upholding most TPO-selected comparables while excluding product-owning entities, clarifying how functional similarity drives benchmarking in software distribution.
