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Income Tax : ICAI Releases Exposure Draft Guidance Note On Report Under Section 92E Of Income-Tax Act, 1961 (Transfer Pricing) Based on the la...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 : ITAT Bangalore remands case for a fresh TP study, directing TPO to assess the applicability of MAP-determined ALP to transactions ...
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 : 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...
The objective of the BEPS Project is to close gaps in international tax rules, effectively eliminating or substantially reducing BEPS; and to secure government revenues by ensuring that profits are taxed in the jurisdiction where the economic activities generating such profits are performed and where value is created.
ITAT held that Revenue has not disputed the fact that effective rate of interest paid by assessee in India was 6.62% on loans whereas Interest paid by assessee on loans taken from AE abroad was 5%. This was below the rate of interest assessee was paying on loans taken within India.
Action plan on Base Erosion and Profit Shifting (‘BEPS’) issued by Organization for Economic Co-Operation and Development’s (‘OECD’) inter alia has proposed to levy a tax on digital transaction to equalize the tax burden on remote and domestic supplier of goods as well as services.
Delhi High Court held In the case of Honda Cars India Limited vs. DCIT that Since the petitioner is not an eligible assessee in terms of Section 144C(15)(b), no draft order can be passed in the case of the petitioner U/s. 144C(1). Section 144C (15)(b) of the Act defines an “eligible assessee”
Central Board of Direct Taxes signed 11 unilateral APAs on 28th March, 2016. With this signing, India has entered into 59 bilateral and/or unilateral APAs. 50 of these agreements have been signed in the current financial year. The agreements cover a range of international transactions, including corporate guarantees, royalty, software development services, IT enabled services and trading.
The finance bill 2016 has introduced three changes that has originated from the BEPS Action plan. What are these BEPS Action plan recommendations and what has it got to do with our Tax systems and economy?
Transfer Pricing, a concept generally used in case of an International as well as Domestic Transactions between interrelated or associated enterprises. These provisions have been introduced to check revenue erosion from India by Multinational companies.
The transfer pricing (TP) provision has come in to place in India fifteen years ago wef AY 2002-03. Since then a number of changes and amendments has been made in the provisions of the TP. It has been a matter of discussion since beginning that when a case should be referred by the AO to the TPO and what the liabilities of the TPO & AO after such reference. The uniformity of procedure of Transfer Pricing is itself a big challenge.
No TP adjustment can be made by deducing from the difference between AMP expenditure incurred by assessee and AMP expenditure of comparable entity, if there is no explicit arrangement between the assessee and its foreign AE for incurring such expenditure.
Delhi High Court held In the case of Denso India Limited vs. CIT that there can be no dispute that the AO would normally accept the figures given in TP report, if they do not call for his interference. However, his job also extends to critically evaluating materials and in cases which do require scrutiny, go ahead and do so.
