Income Tax : Explore the Principal Purpose Test (PPT) in international tax law, its impact on treaty benefits, legal uncertainty, and potential...
Income Tax : Learn about income tax exemptions for universities, hospitals, and educational institutions under Section 10 of the Income Tax Act...
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...
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Income Tax : ICAI Releases Exposure Draft Guidance Note On Report Under Section 92E Of Income-Tax Act, 1961 (Transfer Pricing) Based on the la...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 : Advocate Amardeep Soni & Advocate Harsha Soni Gemplus India Pvt. Ltd. Vs ACIT (ITAT Bangalore) A Case Study of ITAT BANGALORE...
Income Tax : Bangalore ITAT overturns AO's PE classification of QlikTech India, orders fresh review based on TPO order, addresses TDS and inter...
Income Tax : ITAT Bangalore sets aside AO's decision in Qlik Tech International AB vs DCIT, addressing PE classification, TDS credit, and tax r...
Income Tax : ITAT Delhi directs inclusion of Magma Advisory Services Ltd. in Honda R&D's comparable list, rejecting TPO's reasons and DR's func...
Income Tax : ITAT Bangalore deletes AO’s protective addition in LM Wind Power case, citing settled MAP proceedings on IT fees and commission ...
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...
Income Tax : Notification No. 46/2023-Income-Tax Dated: 26th June, 2023 regarding deemed arm's length price for assessment year 2023-2024. Le...
ITAT Delhi held In the case of Alcatel-Lucent Technologies. vs, DCIT that merely because the assessee in the TP study had included the comparable, which was accepted by TPO, it does not follow that the assessee cannot resile from its original claim at a later stage of proceeding
ITAT Mumbai held in Goldman Sachs( India) Securities Pvt. Ltd Vs The DCIT that only functionally comparable company should be compared for comparing the margin percentage of the assessee company with comparable company.
Delhi High Court held In the case of Maruti Suzuki India Ltd. (MSIL) vs. CIT that the transfer pricing adjustment is not expected to be made by deducing from the difference between the ‘excessive’ advertisement
ITAT Bangalore held In the case of M/s. Agila Specialties Pvt. Ltd vs. DCIT that when the data is available showing profit margin of that enterprise itself from a third party, it is always safe and advisable to adopt internal comparable.
ITAT Mumbai held In the case of Greaves Cotton Ltd. vs. ITO that under the transfer pricing regulations, a comparability analysis is a comparison of a controlled transaction with uncontrolled transaction
Those practicing on the international taxation may be aware of the fact that, in view of CBDT Inst no 3/2003[E] and decision of ITAT-SB [C], ALL the transactions above Rs. 15 crores are being referred to TPO for scrutiny and benchmarking.
ITAT Hyderabad upholds AMD R&D’s plea on depreciation impact in transfer pricing. Infosys, L&T, Mindtree excluded. Get insights into the ruling.
The ITAT Ahmedabad in the case of Gemstone Glass Pvt. Ltd vs. JCIT held that when an associated enterprise is taken as comparable then CUP method cannot be adopted for determining Arm Length Price irrespective of the fact that the associated enterprise taken as comparable is resident or non-resident.
Notification 83/2015 in respect of Income Tax Rules, 1962 dated 19th October, 2015 Applicable for determination of arm’s length price of transactions from AY 2015-16 onwards; Applicable for International Transactions as defined u/s 92B & Specified Domestic Transactions as defined u/s 92BA of Income Tax Act. Overview along with steps to incorporate amended Rule 10B […]
Knorr-Bremse India Pvt. Ltd. vs. ACIT (P&H HC) A reading of the orders of the TPO, the DRP and of the Tribunal makes it clear that one of the main reasons for not accepting the assessee’s case was that the assessee had not been able to substantiate that the payment for the services had actually increased its profits.
