Income Tax : Learn about the amendments to Section 92CA concerning references to the Transfer Pricing Officer for determining arm's length pric...
Income Tax : New transfer pricing rules allow arm’s length price (ALP) determinations to apply for two consecutive years, reducing compliance...
Income Tax : Finance Bill 2025 allows multi-year Arm’s Length Price determination for similar transactions, reducing repetitive proceedings i...
Finance : The Finance Bill 2025 proposes multi-year ALP determination to reduce compliance burdens in transfer pricing. Learn about its fram...
Income Tax : Karnataka HC ruled that omission of Section 92BA(i) invalidates its application to domestic transactions, limiting transfer pricin...
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Income Tax : ICAI Releases Exposure Draft Guidance Note On Report Under Section 92E Of Income-Tax Act, 1961 (Transfer Pricing) Based on the la...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 : It was held that transactions and FAR of assessee were similar to AY 2021-22 and as per the records brought to our notice, there...
Income Tax : Respondent/assessee is a Irish company. It accordingly claimed benefits of the India-Ireland DTAA. ADIR is a wholly owned subsidia...
Income Tax : In the matter above-mentioned ITAT partly allowed the appeal filed by the assessee by remanded it back to file of TPO after consid...
Corporate Law : Delhi HC rules that SEB rates, not IEX rates, determine the market price of electricity in transfer pricing cases, dismissing Reve...
Income Tax : ITAT Delhi clarifies tax treatment for Motricity India: No levy on notional income or closure costs. Insights on Transfer Pricing ...
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...
Transfer pricing provisions were earlier restricted to international transactions. With effect from 1.4.2013 , the scope of transfer pricing provisions gets extended to specified domestic transactions (SDT) exceeding Rupees twenty crore.
Mumbai ITAT Ruling – Section 92 of the Act is not an independent charging section to bring in a new head of income or to charge tax on income which is otherwise not chargeable under the Act. Accordingly, the ITAT held that, if no income accrues or arises or is received by the assessee under […]
‘Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting’ (MLI for short) is the official title of the multilateral treaty framework that aims to prevent BEPS. Base erosion and profit shifting (BEPS) refers to artificially shifting profits to low or no-tax locations where there is little or no economic […]
M/s. Enchanting Travels Pvt. Ltd. Vs The Income Tax Officer (ITAT Bangalore) We find that TPO has already taken the total 10 comparables and with respect to 8 comparables, assessee has no objections. With respect to Kerala Travels Interserve Ltd., we have carefully perused its financial statements and we find the main revenue is from different […]
It is seen that the company has completed full-length animated commercial film during the year under consideration. We note that no separate revenue and expenditure on this activity of making animated film is reported in the Annual Report. Since the activity of making animated film is functionally different from the activity of software development services and thus the segment of ‘software development and services’ of the company, cannot be compared with the functions of the assessee.
With respect to opening WDV in case of the foreign company whose PoEM is determined in India and which is assessed to tax in the home jurisdiction, the final notification provides for 2 cases:
Production loss depends on number of factors and in absence of any comparable to show that loss shown by the assessee is excessive, the contention of the assessee has to be accepted
The CBDT has issued the Final Notification No. 29/2018 dated 22 June 2018 (applicable from AY 2017-18) for exception, modification and adaptation in respect of a foreign company said to be resident in India due to its place of effective management (POEM) being in India, under Section 115JH of the Income-tax Act, 1961 (the Act). […]
Draft Notification of exception, modification and adaptation in respect of foreign company said to be resident in India under section 115JH of the Act The Central Board of Direct Taxes (CBDT) on June 15, 2017 issued a Draft Notification (notification) vide F No. 370142/19/2017-TPL for exception, modification and adaptation in respect of foreign company said […]
In transfer pricing disputes, comparability analysis and use of appropriate filters has been one of the most prevalent issues, especially for captive cost plus remuneration service providers.
