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 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 : The Hyderabad ITAT found contradictions in the TPO’s reasoning for excluding a comparable company due to alleged lack of RPT dat...
Income Tax : Pune ITAT held that once TNMM is accepted for a taxpayer’s aggregated international transactions, the TPO cannot isolate a singl...
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...
Reading The ‘Benefit’ Test Into Arm’s Length Price Determination: Throwing The Rulebook Out The Window 1. INTRODUCTION: Transfer Pricing Law, at its core, strikes at the distortion of ordinary business transactions, that occurs when related parties transact on terms inconsistent with competitive market conditions. Reportedly resorted to by Multinational Corporations in some instances, related-party transactions […]
ITAT held that the 10% tolerance band under property valuation provisions applies retrospectively. The PCIT’s revision was set aside as it amounted to a change of opinion.
The Bombay High Court upheld the ITAT’s decision to admit an additional TP ground allowing reconsideration of AEs as the tested party. It held that no substantial question of law arose where the Tribunal remanded the issue for fresh factual examination.
The amendment clarifies how the sixty-day period under transfer pricing law must be calculated. It removes ambiguity that had led to annulment of assessments despite timely action by the TPO.
The proposed changes consolidate all IT and ITeS activities into a single category with a lower, uniform margin and a much higher turnover threshold. The key takeaway is reduced litigation risk and greater pricing certainty for large and mid-sized IT service providers.
The issue concerned valuation of royalty for bundled services. ITAT held that faulty comparables vitiated the CUP analysis and ordered fresh benchmarking.
The issue was whether a transfer pricing adjustment could survive when based solely on DRI allegations later dropped. The Tribunal held that once customs authorities exonerated the assessee, the TP adjustment had no foundation and was rightly deleted.
The case examined whether tax authorities could deny working capital adjustment despite clear prior directions of the Tribunal. The ITAT held that such directions are binding and must be implemented in letter and spirit. Once the adjustment was granted, the assessee’s margin fell within the permissible arm’s length rang
The Tribunal held that AMC services and marketing support services could not be aggregated for transfer pricing purposes. It directed separate segment-wise benchmarking based on functional differences.
The Tribunal held that a manufacturing company failing the 75% trading turnover filter applied by the TPO cannot be retained as a comparable. Dilution of the filter by the DRP only to accommodate one entity was found impermissible, leading to deletion of the comparable.
