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Transfer Pricing

Latest Articles


Demystifying Transfer Pricing

CA, CS, CMA : Learn about transfer pricing, its importance, methods, documentation, penalties for non-compliance, and advanced pricing agreement...

June 29, 2024 396 Views 0 comment Print

Benchmarking Managerial Compensation in UAE: Understanding Transfer Pricing Framework

Income Tax : Understand the UAE's transfer pricing framework and benchmarks for managerial compensation under the new corporate tax law. Ensure...

June 25, 2024 690 Views 0 comment Print

Taxation – The Game of Life – Transfer Pricing & International Taxation

Income Tax : Explore the complexities of international taxation and transfer pricing, crucial for multinational enterprises. Learn about associ...

June 2, 2024 852 Views 0 comment Print

Key takeaways from an M&A perspective from the commentary on Global Anti-Base Erosion Model Rules, 2023

Income Tax : Discover key insights on Global Anti-Base Erosion Model Rules (GloBE) for M&A strategies. Learn about Income Inclusion and Underta...

May 27, 2024 426 Views 0 comment Print

Digital Taxation: Strategies and Implications for Global Economies

Income Tax : Delve into the complexities of digital taxation, exploring its evolution, significance, and global responses. Learn about fair ta...

April 30, 2024 777 Views 0 comment Print


Latest News


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 12234 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Draft Guidance Note on Transfer Pricing Report – Section 92E

Income Tax : ICAI Releases Exposure Draft Guidance Note On Report Under Section 92E Of Income-Tax Act, 1961 (Transfer Pricing) Based on the la...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 25824 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 11652 Views 1 comment Print

Request to extend due dates of Tax Audit Report & Other forms

Income Tax : Voice Of CA has made a Request for Extension of specified date of filing Tax Audit Report and other forms falling due on or before...

January 7, 2022 27855 Views 12 comments Print

Request to Extend Due Dates for filing Tax & Transfer Pricing Audit

Income Tax : Chamber of Tax Consultants has made a Request for Extension of Due Dates for filing Tax Audit and Transfer Pricing Reports to Smt....

January 7, 2022 8577 Views 1 comment Print


Latest Judiciary


Payment by Indian Entity to AE Abroad Not ‘FTS’ if No Technical Skill Provided: Bangalore ITAT

Income Tax : Learn how ITAT Bangalore ruled in favor of Herbalife India on technical service payments, clarifying FTS under India-USA DTAA. Det...

July 4, 2024 327 Views 0 comment Print

ITAT Directs 6% SBI Rate on Delayed Payments in International Transactions

Income Tax : Explore the ITAT Hyderabad's decision on interest as an international transaction in Clinasia Labs Pvt Ltd vs ITO case. Detailed a...

June 21, 2024 345 Views 0 comment Print

RPM is most appropriate method When No Value Addition Before Resale

Income Tax : ITAT Delhi rules RPM as the best method for benchmarking solar goods purchases in the D Light Energy P. Ltd. vs Assessing Officer ...

June 16, 2024 855 Views 0 comment Print

ITAT Rulings on TP Adjustments, ESOP Expenses & Section 14A Disallowance

Income Tax : Tribunal upholds CIT(A) decisions in DCIT Vs Astral Limited case, offering key insights on TP adjustments, ESOP expenses, and Sect...

June 11, 2024 354 Views 0 comment Print

Subsidiary would only be deemed a PE if it satisfies specific tests outlined in DTAA

Income Tax : Delhi High Court quashes reassessment notices by DCIT after TPO settles arm's length remuneration issue. Detailed analysis of Prog...

June 9, 2024 609 Views 0 comment Print


Latest Notifications


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 2847 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 10524 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 1500 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 2328 Views 0 comment Print

Safe Harbour rules for AY 2022-2023 – Income tax Act, 1961

Income Tax : Safe Harbour rules for AY 2022 2023 | Income tax Act, 1961 | Notification No. 66/2022-Income-Tax | Dated: 17th June, 2022 |  CBDT...

June 17, 2022 13653 Views 0 comment Print


Comparability for determining ALP lost as only comparable chosen by DRP fails

November 15, 2023 480 Views 0 comment Print

ITAT Mumbai held that once only comparable as chosen by DRP fails, then same loses the comparability for determining the ALP.

Delhi HC Upholds ITAT’s Decision on Comparables for Arm’s Length Price

November 14, 2023 561 Views 0 comment Print

Delhi High Court supports ITAT’s verdict on the selection of comparables for determining the Arm’s Length Price of an international transaction. Get insights on PCIT vs Chrys Capital

AMP Expenses Not an International Transaction for transfer pricing: Delhi HC

November 14, 2023 393 Views 0 comment Print

Delhi High Court upholds ITAT’s decision: Advertising, Marketing, and Promotion (AMP) expenses by Wrigley India Pvt. Ltd. not considered an international transaction.

Government Shareholders Not Automatically Considered Related Parties

November 12, 2023 282 Views 0 comment Print

In a landmark ruling, the Delhi High Court held that government shareholders are not automatically considered related parties under Section 92E of the Income Tax Act, 1961. This decision has significant implications for companies with government shareholding.

CUP Method Rejection Unwarranted for Uniform Hourly Charges to AEs & Third Parties

November 4, 2023 231 Views 0 comment Print

ITAT that as long as the charges for hourly services provided by appellant were uniform to AEs and third parties, rejection of CUP method was unwarranted.

Penalties for not Maintaining Documents for Specified Domestic Transactions

November 3, 2023 6402 Views 0 comment Print

Penalties for failing to maintain records of specified domestic transactions. Learn about arm’s length pricing & essential document requirements

Delhi HC: Exclusion of OTL Comparable – ITAT to Decide

November 2, 2023 384 Views 0 comment Print

The Delhi High Court directs the ITAT to reconsider the exclusion of Onward Technologies Limited (OTL) as a comparable in the transfer pricing study. Detailed analysis and conclusion.

Delhi High Court Upholds Exclusion of Comparables in Transfer Pricing Case

October 31, 2023 741 Views 0 comment Print

Delhi High Court upheld the exclusion of comparables due to functional dissimilarity and significant turnover differences. Analysis of the PCIT vs. Qualcomm India Pvt Ltd case.

ITAT Deletes Penalty: Failure to file Form No. 3CEB due to CA’s Opinion

October 25, 2023 684 Views 1 comment Print

The Income Tax Appellate Tribunal (ITAT) in Pune deleted the penalty in the Jyoti Paper Udyog Ltd Vs. ACIT case due to non-production of Form No. 3CEB under Section 92E.

Transfer Pricing Rules: Substantial Question of Law or Facts

October 23, 2023 1182 Views 0 comment Print

Explore landmark cases like SAP Labs vs. IT Officer, Evalueserve vs. Commissioner, and Softbrands vs. IT. Learn how the law and facts intersect in transfer pricing disputes.

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