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...
The ITAT Delhi partly allowed the appeal as the AO/TPO selected a company that failed the turnover filter for transfer pricing. Key takeaway: Transfer pricing adjustments must follow proper comparability filters and FAR analysis.
The ruling explains strict compliance requirements for specified domestic transactions, including maintaining detailed documentation for eight years. It highlights that failure to maintain, report, or furnish accurate information attracts penalties of up to 2% of transaction value.
The Tribunal held that a captive software development service provider cannot be compared with giant IT companies owning IP, diversified services, and global operations. By excluding these functionally dissimilar comparables, the entire ₹10.58 crore TP adjustment was deleted.
ITAT emphasized that taxpayers must substantiate the receipt and benefit of group services, remanding the matter due to inadequate examination by lower authorities.
Explains the step-by-step TP study process and highlights common documentation, data, and benchmarking challenges, along with what the analysis ultimately held regarding verification requirements.
The Tribunal applied long-standing rulings invalidating the intensity and BLT approaches for AMP benchmarking, deleting both substantive and protective adjustments. The decision underscores that such methods lack statutory support.
The Tribunal held that the DRP erred in refusing to consider the USAID–AE agreement, which directly established the back-to-back cost-plus-6% model. It ruled that such crucial evidence cannot be dismissed on a procedural technicality and remanded the matter for fresh adjudication.
Tribunal ruled that massive companies like Infosys and TCS cannot be used as comparables when the assessee’s turnover is small, holding that size materially affects profitability. It directed exclusion of such entities and recalculation of margins.
ITAT Delhi held that Transfer Pricing Adjustment made by the revenue on account of administrative support services segment deserves to be deleted since services rendered are in nature of intra group services and not stewardship activity.
ITAT observed that applying an upper turnover filter is essential in transfer pricing cases where the assessee’s turnover is much lower. It ordered exclusion of big IT majors from the comparable list and directed fresh computation of ALP.
