Income Tax : This article explains how Safe Harbour Rules under the Income-tax Act, 2025 interact with APAs, MAP provisions, and transfer prici...
Income Tax : The framework outlines mandatory disclosures and timelines for opting into safe harbour. Key takeaway: strict compliance is essent...
Income Tax : The article explains how safe harbour rules simplify transfer pricing compliance. It highlights that eligible transactions are acc...
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 : 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 : ITAT Delhi held that television channel and content owner companies could not be compared with a content distribution business. Th...
Income Tax : ITAT Mumbai held that distribution fees paid to associated enterprises could not be treated as royalty. The Tribunal followed earl...
Income Tax : ITAT Mumbai deleted the transfer pricing adjustment on management fees after finding that identical issues in the assessee’s own...
Income Tax : The ITAT held that transfer pricing adjustment was not justified where the foreign LLC’s income was already offered to tax in In...
Income Tax : ITAT Ahmedabad held that transfer pricing authorities cannot assign a NIL arm’s length price when the assessee has demonstrated ...
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...
Microsoft Corporation (India) Pvt Ltd Vs DCIT (ITAT Delhi) The issue under consideration is whether expenditure on account of civil and interior works liable for depreciation at 10% or at 15%? ITAT states that, they have perused the items of the expenditure which has been reproduced by the assessing officer in the assessment order and […]
In this article you will find detailed analysis of certain terms and issues which either OECD or certain other countries have clarified. Notification in respect of BEPS Action plan 13 is expected shortly from CBDT.
CbCR (Country by Country Report) is one of the recent amendment which has created a lot of hue and cry in the industry, hence here in this article the author will provide the basic concepts related to CbC reporting for all the Chartered Accountants.
Section 92A (1) of the act provides that two enterprises shall be treated as Associated enterprises only when one of the enterprises participates in management, control or capital of the other enterprise.
This article provides a comprehensive summary of the efforts undertaken by OECD in addressing the issues relating to the Tax Challenges Arising from the Digitalisation of the Economy. The article then discusses the intricacies of the proposed Unified Approach issued by OECD Secretariat and endorsed by the OECD Inclusive Framework on Base Erosion and Profit Shifting Project.
Transfer Pricing provisions in Chapter X of the I-T Act 1961 entitled Special Provisions Relating to Avoidance of Tax enables the Transfer Pricing Officer in determining the Arm’s Length Price (ALP) in relation to an international transaction between Associated Enterprises commonly referred as controlled transaction, by using the Most Appropriate Method (MAM) from the prescribed methods under Section 92C (1) of the Act.
Though erstwhile rules 44G and 44H were in existence for a number of years, detailed information regarding MAP processes and guidance on issues related to such processes were not available in a comprehensive and consolidated manner.
Global Logic India Ltd. Vs ACIT (ITAT Delhi) Now coming to the next issue raised in the present appeal against the transfer pricing adjustment made on account of interest due on receivables outstanding. The said issue stands covered in favour of the assessee by the decision of the Tribunal in assessee’s own case for Assessment […]
It is not open to the revenue authorities to recharacterize the transaction unless it is found to be a sham or bogus transaction. While there are no specific powers vested in the TPO to recharacterize the transaction, even under the judge made law, such rechracterization can be done by the revenue authorities when the transactions are found to be substantially at variance with the stated form.
In Transfer pricing proceedings, corporate guarantee given by assessee to its foreign AE is always disputed by the department as an international transaction and adjustment determined on the basis of average bank guarantee rates. However, in number of judgements by tribunal and HC, the stand of the department is overruled and relief granted to the assessee.
