Income Tax : Delve into the complexities of digital taxation, exploring its evolution, significance, and global responses. Learn about fair ta...
Income Tax : Discover the intricacies of structuring cross-border mergers and acquisitions (M&A). Learn about key steps, due diligence, legal c...
Income Tax : Country-by-Country Reporting (CbCR) is a crucial component of the transfer pricing documentation requirements introduced by the Or...
Income Tax : Learn about Transfer Pricing compliance and assessment procedures, including ALP determination, TPO reference, DRP mechanism, APAs...
Income Tax : Explore the significance of transfer pricing in international taxation and corporate finance. Learn about arm's length pricing, me...
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Income Tax : ICAI Releases Exposure Draft Guidance Note On Report Under Section 92E Of Income-Tax Act, 1961 (Transfer Pricing) Based on the la...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 : 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...
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....
Income Tax : Delhi High Court rules AO can't deviate from Transfer Pricing Officer's determined Arm's Length Price (ALP) in international trans...
Income Tax : Learn from PCIT Vs Radhashir Jewellery Co. Pvt Ltd. case why comparing new and established businesses in transfer pricing is inapp...
Income Tax : Analysis of Maharashtra Seamless Ltd Vs DCIT case where no transfer pricing adjustment was needed as the assessee earns interest a...
Income Tax : Delhi High Court rules in favor of Oriflame India Pvt Ltd, withdrawing TPO's proposed income adjustments, applies TNMM over RPM. D...
Income Tax : Calcutta High Court dismisses PCIT's appeal, reaffirming that the least complex party should be the tested entity in transfer pric...
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...
Income Tax : Safe Harbour rules for AY 2022 2023 | Income tax Act, 1961 | Notification No. 66/2022-Income-Tax | Dated: 17th June, 2022 | CBDT...
ITAT Mumbai held that the Indian Subsidiary operating in an independent manner doesn’t constitute as a “Permanent Establishment” in India and hence income of the assessee is not allowable to be taxed in India.
Read how ITAT Delhi deleted ALP adjustment in STEAG Energy Services vs. ACIT case, as it falls within tolerance band of +/- 5% under Section 92C(2) of Income Tax Act.
ITAT Delhi deleted TP adjustment on payment of model fee for export to AEs stating that scope of TPO is limited to determination of arm’s length price and TPO cannot adjudge commercial expediency of a transaction.
Finance Act, 2017 removed clause (i) of section 92BA, effectively nullifying any decisions made by the Assessing Officer under this section. Reference to the TPO under section 92CA also becomes invalid
ITAT Mumbai held that addition towards lower commission charged by Jetair Pvt. Ltd. to Jet Airways (India) Ltd. on account of Online Reservation Commission by applying arm’s length price not sustained as the transaction was neither international transaction nor a specified domestic transaction and hence transfer pricing provisions doesn’t apply.
Bombay High Court held that the transaction of payment of royalty for use of technology is inextricably linked with manufacturing activity and should be aggregated with other international transactions in the manufacturing segment for the purposes of benchmarking the same
ITAT Hyderabad held that Transactional Net Margin Method (TNMM) was the most appropriate method in the absence of a Comparable Uncontrolled Price (CUP) which is applicable to the payment of technical service fee which is in nature of intangibles.
ITAT Mumbai held that as per section 92CA(3) TPO order should be passed before 60 days prior to the date prescribed u/s 153 of the Act. Accordingly, in present case, TPO order passed on 30/01/2015 instead of 29/01/2015 is non-est and liable to be quashed as being barred by limitation.
Read how CBDT’s Notification No. 58/2023 amends Income-tax Rules, extending Safe Harbour rules to AY 2023-24. Insights from Ministry of Finance, New Delhi.
Read the full text of the Delhi High Court judgment in the CIT vs. Sumitomo Corporation India Pvt Ltd case, concerning Assessment Years 2012-13 and 2013-14. TNMM found suitable for determining ALP for international indenting-transactions.
