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Income Tax : ICAI Releases Exposure Draft Guidance Note On Report Under Section 92E Of Income-Tax Act, 1961 (Transfer Pricing) Based on the la...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...
Introduction As we know the Finance Act 2012 has extended the scope of Transfer Pricing provisions to ‘Specified Domestic Transactions’ (SDT) between related parties w.e.f. AY 2013-14 by inserting section 92BA. Since its introduction there was ambiguity on its applicability to cooperative societies. There was no doubt of its applicability to cooperative societies claiming profit […]
ITAT Bangalore held In the case of DCIT vs. M/s. Parametric Technology (India) Pvt. Ltd. that the use of current year’s data is mandated by the relevant I.T. Rules, 1962 and by not adhering to this, the assessee’s TP Study was rendered unreliable.
In this case of Trend Micro India Pvt. Ltd. Vs. DCIT Delhi Bench of ITAT observed that whether revenue can argue against the order passed by AO in pursuance to the directions of DRP. The ITAT held that it is not permissible to argue any issue decided by AO by DR before tribunal.
ITAT held in Acclaris Business Solutions Lvt Ltd. Vs I.T.O that only those companies could be compared for calculating ALP which were functionally similar. Those companies which were not performing similar functions could not be compared for calculating ALP.
ITAT held in Haier Appliances India Ltd Vs DCIT and Haier Appliances India Ltd Vs ACIT after relying on the case of Sony Ericsson Mobile Communications India Pvt Ltd reported in (2015) 374 ITR 118 (Delhi) that the above transaction of AMP
CIT Vs. V/s. M/s. Thyssen Krupp Industries India Pvt. Ltd. (Bombay High Court) In terms of Chapter X of the Act, redetermination of the consideration is to be done only with regard to income arising from International Transactions on determination of ALP.
CIT Vs. V/s. M/s. Thyssen Krupp Industries India Pvt. Ltd. (Bombay High Court) Whether on the facts and the circumstance of the case and law, the Tribunal was justified in law in restricting the Transfer Pricing (TP) adjustment only to the transaction between the Associated Enterprises (AEs.)?
ITAT Bangalore held In the case of M/s. Meritor LVS India (P) Ltd. vs. ACIT that the transfer pricing officer (TPO) has drawn conclusions on the basis of information obtained by issue of notice u/s.133(6) .This information which was not available in public domain could not have been used by the TPO,
ITAT Delhi held In the case of Xchanging Technology Services India Private Limited. vs, DCIT that the Hon’ble High Court affirmed the conclusion that a captive unit of a comparable company which assumed only a limited risk cannot be compared with a giant company in the area of development
ITAT Delhi held In the case of Honda Trading Corporation. vs, DCIT that despite the use of the word `may’, the time limit for passing the order by the TPO is mandatory, as in the otherwise situation of the TPO having been allowed more time by implication
