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 Delhi held that television channel and content owner companies could not be compared with a content distribution business. Th...
Income Tax : ITAT Mumbai held that distribution fees paid to associated enterprises could not be treated as royalty. The Tribunal followed earl...
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 : 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...
Finance Act, 2017 inserted a new Section 92CE in the Income-tax Act, 1961 with effect from 1st day of April, 2018 to provide for secondary adjustment by attributing income to the excess money lying in the hands of the associated enterprise.
The CBDT has released the final rules through notification (N No. 3497(E) on preparation and filing of Master file by the Constituent Entity of an International group. The brief of the rules as notified and the documentation requirements as needed for the filing are summarized below:
The Central Board of Direct Taxes (CBDT), has released the final rules through a notification (N No. 3497(E) on preparation and filing of Master file by the Indian Entity of an International group. The brief of the rules as notified and the documentation/information requirements as needed for the filing are summarized herewith for your reference.
If a company is having huge asset base, brand value, goodwill and presence in global market with significant R & D, then it cannot be compared with a company which is purely captive service provider in ITeS/BPO, having low risk and insignificant assets.
Tax havens create huge challenges before countries in terms of shifting of profits, flight of capital, hiding of unaccounted wealth & other assets of tax residents of countries and providing a safe haven for parking corruption proceeds from where it is ultimately laundered back into source countries.
Two issues are important for determining the arm’s length price of the services provided to foreign affiliate by an Indian service provider. These are proper determination of cost base on which arm’s lengthy mark- up will apply and the mark-up. The article deals with the issue of constituents of cost base. Hopefully, the proper determination of cost base by the assessee and in the transfer pricing audit will help in collection of due taxes in India.
In order to overcome the issue of double taxation, the concept of Permanent Establishment (PE) was introduced. Taking a step back into the first treaty on double taxation, the provision provides that business profits made by a PE were to be taxed in the country where the PE is situated.
Transfer Pricing: Suggested Operating Profit Margins for IT and ITeS Sector having Turnover between Rs. 50 lakhs to Rs. 50 crores This is high time for the entities which have to comply with the provisions of Transfer Pricing (TP) under Income-tax Act, 1961 (the Act) i.e. only 5 days left for filing of the various […]
The Finance Act, 2016 introduced provisions relating to Country by Country Report (CbCR) and Master File pursuant to adoption of OECD’s BEPS Action Plan-13 in India. On 31st October 2017, CBDT released the Final Rules with respect to maintenance and furnishing of Master File and CbCR. Summary of Final Forms and Rules for Master-File applicable […]
POEM is the place where the ‘key management and commercial decisions that are necessary for the conduct of business of an entity as a whole are, in substance made. NEED: This concept is the test of residence for foreign companies to provide that a company would be treated as resident in India if its POEM in the previous year is in India for tax purposes.
