Income Tax : Learn about the amendments to Section 92CA concerning references to the Transfer Pricing Officer for determining arm's length pric...
Income Tax : New transfer pricing rules allow arm’s length price (ALP) determinations to apply for two consecutive years, reducing compliance...
Income Tax : Finance Bill 2025 allows multi-year Arm’s Length Price determination for similar transactions, reducing repetitive proceedings i...
Finance : The Finance Bill 2025 proposes multi-year ALP determination to reduce compliance burdens in transfer pricing. Learn about its fram...
Income Tax : Karnataka HC ruled that omission of Section 92BA(i) invalidates its application to domestic transactions, limiting transfer pricin...
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 : 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Income Tax : ICAI Releases Exposure Draft Guidance Note On Report Under Section 92E Of Income-Tax Act, 1961 (Transfer Pricing) Based on the la...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 : It was held that transactions and FAR of assessee were similar to AY 2021-22 and as per the records brought to our notice, there...
Income Tax : Respondent/assessee is a Irish company. It accordingly claimed benefits of the India-Ireland DTAA. ADIR is a wholly owned subsidia...
Income Tax : In the matter above-mentioned ITAT partly allowed the appeal filed by the assessee by remanded it back to file of TPO after consid...
Corporate Law : Delhi HC rules that SEB rates, not IEX rates, determine the market price of electricity in transfer pricing cases, dismissing Reve...
Income Tax : ITAT Delhi clarifies tax treatment for Motricity India: No levy on notional income or closure costs. Insights on Transfer Pricing ...
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...
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...
We also note that the Delhi High Court in Commissioner of Income Tax Vs. Keihin Panalfa Ltd. (ITA No.11 of 2015) decided on 9th September, 2015 has while dealing with transfer pricing adjustment in the absence of segmental accounts held that adjustments have to be restricted only to transactions with Associated Enterprises. It further held that whereseparate accounts are not available, then proportionate adjustments to be made only in respect of the international transactions with Associated Enterprises.
Rule. Mrs. Mauna N. Bhatt, learned advocate waives service of notice of rule on behalf of the respondents. In the facts and circumstances of the case and with the consent of the learned advocates appearing for the respective parties, the present petition is taken up for final hearing today.
Anomaly between the provision of Finance Bill and Memorandum explaining the Finance Bill- Interestingly the phraseology used in Memorandum explaining the provisions of The Finance Bill 2017 and Finance Bill 2017 to calculate the excess interest is ambiguous and results in different outcome.
Finance Act, 2012 has made an amendment to extend the Transfer Pricing Provisions to the transactions entered with domestic related parties or by an undertaking with other undertakings of the same entity for the purposes of section 40A, chapter VI-A and section 10AA.
Budget 2017- it is proposed to provide that expenditure in respect of which payment has been made by the assessee to a person referred to in under section 40A(2)(b) are to be excluded from the scope of section 92BA of the Act. Accordingly, it is also proposed to make a consequential amendment in section 40(A)(2)(b) of the Act.
Country’s tax administrations often introduce rules that place a limit on the amount of interest that can be deducted in computing a company’s profit for tax purposes. Such rules are designed to counter cross-border shifting of profit through excessive interest payments, and thus aim to protect a country’s tax base.
Hon’ble Supereme Court admits SLP- Transer pricing adjustment should be restriced to AE transactions only and not on entire turnover of assessee
Business restructuring refers to the cross-border re-organisation of the commercial or financial relations between associated enterprises, including the termination or substantial renegotiation of existing arrangements.
To calculate an effective royalty rate for a comparison with a third party royalty rate, one may have to not only determine what will be the future economic benefit that may arise in the form of cash flows but also convert them into a rate (say as a percentage of sales).
ITAT held that on account of extra ordinary events viz. acquisition of IQ group of companies and amalgamation of Accentia Infoserve Pvt. Ltd with Accentia Technologies Ltd, the said company cannot be considered as good comparable.
