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...
M/s. Barco Electronic Systems (P.) Ltd. Vs. DCIT (ITAT Delhi) Facts of the Case ♣ Barco Electronic Systems Pvt. Ltd. ( taxpayer) is engaged in business of manufacturing of projectors and parts, trading in visual display products and provision of software development services. ♣ During the year under consideration, the taxpayer entered into various international […]
Download comprehensive cases summary of Captive Service Providers- January 2019 to July 2019 from the link given below-
Bright line test is not an appropriate yardstick for determining existence of an international transaction for calculating arms length price.
Whereas the Multilateral Convention to Implement Tax Treaty related Measures to Prevent Base Erosion and Profit Shifting (hereinafter referred to as the “the said Convention”) was signed by India at Paris, France on the 7th day of June, 2017;
As the actor Shilpa Shetty was a brand ambassador for IPL team Rajasthan Royals, she was bound to render certain services without any charge to subsidiary company JIPL owned by holding company of her husband and assessee did not receive any consideration for the services rendered to JICPL, in the absence of any ‘price’, the provision of services could not be considered as an ‘international transaction under sec. 92(1).
♣ Secondary Adjustment has been inserted vide section 92CE by the Finance Act, 2017, in order to align TP provisions with OECD TP Guidelines and “international best practices”. ♣ Secondary adjustment means an adjustment in the books of accounts of the taxpayer and its associated enterprise (‘AE’) to reflect that the actual allocation of profits […]
A substantial volume of global trade comprises transactions between related enterprises within groups of multinational enterprises (MNEs). The transactions between such related or associated enterprises may take place under conditions different from those taking place between independent enterprises.
The Income tax Act 1961, has prescribed penal provisions for default in compliance with the provisions of the a TP regulations, which are summarized below: Nature of default Relevant Section of the Act Nature of penalty Under Reporting of income arising in the cases other than the case referred in sub section (9) 270A(2) read […]
Significant economic presence shall mean–i. Any transaction in respect of any goods, services or property carried out by a non-resident in India including provision of download of data or software in India if the aggregate of payments arising from such transaction or transactions during the previous year exceeds the amount as may be prescribed; or
CIT Vs M/s. Glenmark Pharmaceuticals Ltd. (Supreme Court of India) Hon;ble Supreme Court Upheld the Judgment of Hon;ble HIgh Court and held that Arm’s length price of corporate guarantee could not be determined on the basis of comparison with bank guarantee and as such, High Court rightly affirmed the view taken by ITAT deleting the […]
