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...
Section 94B, was inserted by the Finance Act, 2017, w.e.f. 01.04.2018 which provides that interest expenses claimed by a Company to its associated enterprises shall be restricted to 30% of its earnings before interest, taxes, depreciation and amortization (EBITDA) or interest paid or payable to associated enterprise, whichever is less.
The issue under consideration is whether the deletion of adjustment made u/s 92CA(3) of the Act on account of interest on loan and on account of corporate guarantees is justified in law?
Where assessee failed to upload the report electronically in Form No. 3CEB but said report was promptly made available in the assessment proceedings itself, said failure was accepted as bona fide and accordingly, the penalty levied under section 271BA was to be quashed.
CBDT amends Rule 10CB relating to interest income computation for secondary adjustments (Notification No. 76/2019/ F.No.370142/12/2017-TPL) Introduction The Finance Act, 2017 inserted Section 92CE in the Income-tax Act, 1961 (the Act) w.e.f. 1 April, 2018 to provide for secondary adjustment, where, as a result of primary adjustment to the transfer price, there is an increase […]
CBDT Amends Income Tax Rule 10CB -Computation of interest income pursuant to secondary adjustments vide Notification No. 76/2019-Income-tax dated 30th September, 2019. MINISTRY OF FINANCE (Department of Revenue) (CENTRAL BOARD OF DIRECT TAXES) New Delhi, the 30th September, 2019 Notification No. 76/2019-Income-tax G.S.R. 701(E).—In exercise of the powers conferred by sub-section (2) of section 92CE […]
In our recent discussions, we had come across that many of the business people and few of the professionals were not aware/familiar with the Transfer Pricing (TP) provisions and the related compliances. This document is intended to provide the basic knowledge of the same.
Base Erosion Profit Shifting (‘BEPS’) Action Plan Weakness of international tax system created several opportunities for tax payers for shifting profits to tax friendly jurisdictions. To create transparency, exchange of information and to avoid treaty abuse, G20 leaders endorsed BEPS Action Plan and developed the same with Organisation of Economic Co-operation and Development (‘OECD’). BEPS […]
Notification No. 64/2019- Income Tax provides for tolerance range of one per cent. for wholesale trading and three per cent. in all other cases for assessment year 2019-20. It is certified that none will be adversely affected by the retrospective effect being given to the notification. MINISTRY OF FINANCE (Department of Revenue) New Delhi Notification […]
Times Global Broadcasting Company Ltd Vs Union of India & Ors. (Bombay High Court) It is indisputable that by virtue of sub-sections (2A) and (2B) of Section 92CA, in case of an international transaction, the TPO would have an authority to examine any international transaction which comes to his notice during the proceedings, whether a […]
In view of the guidelines issued by the CBDT in Instruction 3/2003 the Tribunal was right in observing that by not making reference to the TPO, the Assessing Officer had breached the mandatory instructions issued by the CBDT.
