Sponsored
    Follow Us:

Transfer Pricing

Latest Articles


Budget 2025: Transfer Pricing Amendments

Income Tax : Learn about the amendments to Section 92CA concerning references to the Transfer Pricing Officer for determining arm's length pric...

February 4, 2025 963 Views 0 comment Print

Transfer Pricing Amendments: Multi-Year ALP Determination

Income Tax : New transfer pricing rules allow arm’s length price (ALP) determinations to apply for two consecutive years, reducing compliance...

February 3, 2025 672 Views 0 comment Print

Transfer Pricing: Multi-Year ALP Determination in Budget 2025 – FAQs

Income Tax : Finance Bill 2025 allows multi-year Arm’s Length Price determination for similar transactions, reducing repetitive proceedings i...

February 2, 2025 555 Views 0 comment Print

Finance Bill 2025: Amendment related to Transfer Pricing

Finance : The Finance Bill 2025 proposes multi-year ALP determination to reduce compliance burdens in transfer pricing. Learn about its fram...

February 1, 2025 1023 Views 0 comment Print

Section 92BA(i) Prevision Treated as Never Existed: Karnataka HC

Income Tax : Karnataka HC ruled that omission of Section 92BA(i) invalidates its application to domestic transactions, limiting transfer pricin...

January 24, 2025 354 Views 0 comment Print


Latest News


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 951 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 468 Views 0 comment Print

FAQ’s on filing of Income Tax Form 3CEB

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...

October 28, 2022 13557 Views 0 comment Print

Draft Guidance Note on Transfer Pricing Report – Section 92E

Income Tax : ICAI Releases Exposure Draft Guidance Note On Report Under Section 92E Of Income-Tax Act, 1961 (Transfer Pricing) Based on the la...

July 21, 2022 26124 Views 1 comment Print

ACAE Requested due date extension for filing Tax & TP Audit

Income Tax : Association for Corporate Advisers and Executives (ACAE) made a Request for Extension of Due Dates for filing Tax Audit and Transf...

January 7, 2022 11787 Views 1 comment Print


Latest Judiciary


ITAT Directs Fresh TP Study for Non-US AEs After MAP Resolution

Income Tax : ITAT Bangalore remands case for a fresh TP study, directing TPO to assess the applicability of MAP-determined ALP to transactions ...

February 21, 2025 57 Views 0 comment Print

Relief to Bloomsbury Publishing in Transfer Pricing Case

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...

February 17, 2025 78 Views 0 comment Print

Indian AE Transactions at Arm’s Length, HC Says No More Attribution

Income Tax : Respondent/assessee is a Irish company. It accordingly claimed benefits of the India-Ireland DTAA. ADIR is a wholly owned subsidia...

February 13, 2025 117 Views 0 comment Print

Taxpayer Must Provide Comparable Data in Foreign AE Cases:: ITAT remanded matter

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...

February 13, 2025 102 Views 0 comment Print

State Electricity Board Rates Determine Market Price of Power: Delhi HC

Corporate Law : Delhi HC rules that SEB rates, not IEX rates, determine the market price of electricity in transfer pricing cases, dismissing Reve...

January 29, 2025 447 Views 0 comment Print


Latest Notifications


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 1227 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 3687 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 11877 Views 0 comment Print

Deemed Arm’s Length Price for Assessment Year 2023-2024

Income Tax : Notification No. 46/2023-Income-Tax Dated: 26th June, 2023  regarding deemed arm's length price for assessment year 2023-2024. Le...

June 26, 2023 1722 Views 0 comment Print

Tolerance Band for AY 2022-23 in case of wholesale trading & others

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...

June 28, 2022 2628 Views 0 comment Print


Texport Overseas: Analysis of Case on omission of Section 92BA(i) from Income-tax Ac

January 15, 2018 4239 Views 1 comment Print

In the recent landmark judgement of Texport Overseas Private Limited v. DCIT [IT(TP)A No. 1722/Bang/2017], Honorable Bangalore Tribunal held that: it would be deemed that clause (i) of Section 92BA of the Income-tax Act, 1961 (‘the Act”) was never been on the statute as it has been omitted w.e.f. April 01, 2017 vide Finance Act, 2017 and nothing was specified whether the proceeding initiated or action taken on this continue.

Compute working capital adjustment using OECD methods: ITAT upheld DRP direction

January 4, 2018 5370 Views 0 comment Print

Whether the observations of Honble DRP is right in directing the TPO to give working capital adjustment [using OCED methodology given in Annexure to chapter – 3 and applying SBI Prime Lending Rate (as on 30th June of the relevant financial year) as the interest rate] against the TPO order dated 16.01.2014 passed u/s 92CA(3) for A.Y. 2010-11.

No Penalty If determination of ALP not leads to any TP Adjustment, with no effect on income of assessee

December 27, 2017 2649 Views 0 comment Print

Since, the determination of arm’s length price in the appeal effect order has not lead to any transfer pricing adjustment, with no effect on income of the assessee, hence, penalty provisions are not applicable in this case, therefore, we cancel the orders of the authorities below thereby deleting the penalty in dispute.

Omission of SDT by Finance Act 2017, renders it non-existent from inception: ITAT Bangalore

December 22, 2017 4782 Views 0 comment Print

Whether the omission of reference of section 40A(2)(b) from section 92BA by virtue of the amendment of Finance Act, 2017 w.e.f. 01.04.2017 shall be deemed not to be on the statute since its introduction w.e.f. 01.04.2012?

Omission of clause from statue- Deemed to be from inception or not?

December 22, 2017 2232 Views 0 comment Print

Pursuant to the amendment made by Finance Act 2017, omission of clause (i) of Section 92BA of the IT Act, 1961 be deemed to be removed from statute since the beginning until and unless there is some saving clause or provision that pending proceedings shall be continued and be disposed off under old rules.

Payment of Arbitration Award cannot form part of Cost Base for Margin Calculation

December 10, 2017 1134 Views 0 comment Print

ITAT Delhi, last week held that the transaction of making payment of Rs. 95,50,31,150/- (on account of arbitral award) by Hyundai Rotem Company to the DMRC made on behalf of its AE would not part of the margin calculation to be added to revenue and cost for bench marking the international transaction.

Penalty for transfer pricing adjustment not justified if ALP was determined in good faith and with due diligence

December 3, 2017 3234 Views 0 comment Print

A division bench of the Delhi ITAT, last week held that penalty under section 271(1)(c) of the Income Tax Act, 1961 cannot be levied if the Arm’s Length Price (ALP) was determined as per the scheme of section 92C in good faith and with due diligence.

Difference of opinion between CIT(A) & TPO cannot per se be a ground for interference

December 1, 2017 1050 Views 0 comment Print

Pr. CIT Vs Makemy Trip India Pvt. Ltd. (Delhi High Court) The Court is of the opinion that no substantial question of law arises. The difference of opinion between the CIT(A) and the TPO, as to the appropriateness of one or the other methods, cannot per se be a ground for interference; the appropriateness of […]

ALP adjustment for excess credit period to AEs without charging any interest

November 28, 2017 1206 Views 0 comment Print

ITAT Bengaluru held in the case of Nuance Transcription Services India (P.) Ltd. v Dy. CIT that Outstanding Receivables from AE is an international transaction as per Explanation to Section 92B inserted by the Finance Act 2012 and non-charging of interest for a period exceeding 6 months requires ALP adjustment.

Acceptance of Transfer Pricing MAP and bilateral APA – Reg.

November 27, 2017 1104 Views 0 comment Print

Clarification of India’s position on the acceptance of MAP and bilateral APA in cases of countries where Article 9(2) of OECD Model Tax Commentary is absent

Sponsored
Sponsored
Search Post by Date
February 2025
M T W T F S S
 12
3456789
10111213141516
17181920212223
2425262728