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Transfer Pricing

Latest Articles


Future of International Taxation: OECD Global Minimum Tax

Income Tax : Learn about income tax exemptions for universities, hospitals, and educational institutions under Section 10 of the Income Tax Act...

March 11, 2025 525 Views 0 comment Print

Budget 2025: Transfer Pricing Amendments

Income Tax : Learn about the amendments to Section 92CA concerning references to the Transfer Pricing Officer for determining arm's length pric...

February 4, 2025 1206 Views 0 comment Print

Transfer Pricing Amendments: Multi-Year ALP Determination

Income Tax : New transfer pricing rules allow arm’s length price (ALP) determinations to apply for two consecutive years, reducing compliance...

February 3, 2025 810 Views 0 comment Print

Transfer Pricing: Multi-Year ALP Determination in Budget 2025 – FAQs

Income Tax : Finance Bill 2025 allows multi-year Arm’s Length Price determination for similar transactions, reducing repetitive proceedings i...

February 2, 2025 612 Views 0 comment Print

Finance Bill 2025: Amendment related to Transfer Pricing

Finance : The Finance Bill 2025 proposes multi-year ALP determination to reduce compliance burdens in transfer pricing. Learn about its fram...

February 1, 2025 1272 Views 0 comment Print


Latest News


Tolerance Range for Transfer Pricing Notified for AY 2024-25

Income Tax : CBDT sets transfer pricing tolerance range at 1% for wholesale trading and 3% for other transactions for AY 2024-25, providing cla...

October 30, 2024 1020 Views 0 comment Print

Budget 2024: TPO can evaluate SDTs not reported by taxpayers

Income Tax : From April 2025, TPOs can determine ALP for SDTs not initially referred or reported. This ensures accurate adjustments and complia...

July 26, 2024 516 Views 0 comment Print

FAQ’s on filing of Income Tax Form 3CEB

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...

October 28, 2022 13632 Views 0 comment Print

Draft Guidance Note on Transfer Pricing Report – Section 92E

Income Tax : ICAI Releases Exposure Draft Guidance Note On Report Under Section 92E Of Income-Tax Act, 1961 (Transfer Pricing) Based on the la...

July 21, 2022 26145 Views 1 comment Print

ACAE Requested due date extension for filing Tax & TP Audit

Income Tax : Association for Corporate Advisers and Executives (ACAE) made a Request for Extension of Due Dates for filing Tax Audit and Transf...

January 7, 2022 11808 Views 1 comment Print


Latest Judiciary


Cost Allocation and Transfer Pricing – ITAT Bangalore Ruling

Income Tax : Advocate Amardeep Soni & Advocate Harsha Soni Gemplus India Pvt. Ltd. Vs ACIT (ITAT Bangalore) A Case Study of ITAT BANGALORE...

March 19, 2025 306 Views 0 comment Print

Fresh Adjudication Ordered on TPO Adjustment in Subsidiary Transaction

Income Tax : Bangalore ITAT overturns AO's PE classification of QlikTech India, orders fresh review based on TPO order, addresses TDS and inter...

March 9, 2025 78 Views 0 comment Print

Indian Subsidiary Not a Dependent Agency PE if Transactions Are Subject to TPO Adjustment

Income Tax : ITAT Bangalore sets aside AO's decision in Qlik Tech International AB vs DCIT, addressing PE classification, TDS credit, and tax r...

March 8, 2025 156 Views 0 comment Print

Comparable cannot be excluded in Absence of Persistent Losses: ITAT Delhi

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...

February 28, 2025 168 Views 0 comment Print

Protective Addition Unsustainable if Substantial Addition is Confirmed or Settled: ITAT Bangalore

Income Tax : ITAT Bangalore deletes AO’s protective addition in LM Wind Power case, citing settled MAP proceedings on IT fees and commission ...

February 27, 2025 198 Views 0 comment Print


Latest Notifications


Tolerance Range for Arm’s Length Price in FY 2024-25

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...

October 18, 2024 1395 Views 0 comment Print

Income-tax (Twenty-Ninth Amendment) Rules, 2023

Income Tax : Stay informed on the latest Income Tax Rule changes with Notification No. 104/2023 by the Ministry of Finance. Learn about amendme...

December 19, 2023 3723 Views 0 comment Print

CBDT extends applicability of Safe Harbour rules to AY 2023-24

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...

August 9, 2023 11955 Views 0 comment Print

Deemed Arm’s Length Price for Assessment Year 2023-2024

Income Tax : Notification No. 46/2023-Income-Tax Dated: 26th June, 2023  regarding deemed arm's length price for assessment year 2023-2024. Le...

June 26, 2023 1737 Views 0 comment Print

Tolerance Band for AY 2022-23 in case of wholesale trading & others

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...

June 28, 2022 2646 Views 0 comment Print


Significant differences in product segments & marketing strategies: ITAT excludes comparable

March 19, 2024 297 Views 0 comment Print

Delhi High Court rules in favor of Oriflame India Pvt Ltd, withdrawing TPO’s proposed income adjustments, applies TNMM over RPM. Details of the case analysis here.

In Transfer pricing associated enterprises can be selected as a tested party: Calcutta HC

March 19, 2024 372 Views 0 comment Print

Calcutta High Court dismisses PCIT’s appeal, reaffirming that the least complex party should be the tested entity in transfer pricing transactions, citing relevant precedents.

Comparative analysis of Mutual agreement Procedure & Advance pricing agreement

March 16, 2024 1686 Views 0 comment Print

Learn about Advance Pricing Agreements (APAs) and Mutual Agreement Procedures (MAPs) in international taxation. Understand their effectiveness, compliance, and applicability in resolving transfer pricing disputes.

Transfer Pricing: Comparability Analysis and Functional Analysis

March 9, 2024 3207 Views 0 comment Print

Maximize transfer pricing accuracy with our guide on Comparability and Functional Analysis, aligning transactions with the arm’s length principle for compliance and strategic insights.

Action Plans 8-10: Aligning Transfer Pricing Outcomes with Value Creation 

March 7, 2024 744 Views 0 comment Print

Actions 8-10 of the Base Erosion and Profit Shifting (BEPS) agenda aim to address misapplications of international transfer pricing rules. These misapplications result in profit allocations not aligned with the economic activities generating them.

Action 13 of BEPS Action Plan on Transfer Pricing Documentation

March 7, 2024 918 Views 0 comment Print

Explore the comprehensive requirements of Action 13 of the BEPS Action Plan on transfer pricing documentation, including local file, master file, and country-by-country reporting. Learn about implementation thresholds and India’s incorporation of these standards.

Exclusion of Comparables Unjustified if Financial Data Can Be Reasonably Extrapolated: ITAT

March 3, 2024 858 Views 0 comment Print

ITAT Mumbai rules that comparables cannot be excluded if their financial data can be reasonably extrapolated, in Syngenta Services Private Limited’s case.

Evolution of OECD’s concept of Harmful Tax Practices: From 1998 Report to BEPS Action 5 Approach

February 21, 2024 501 Views 0 comment Print

Explore the evolution of harmful tax practices from the OECD’s 1998 report to the BEPS Action 5 approach, focusing on transparency, substantial activity requirements, and the eradication of harmful regimes.

No Section 271G Penalty Without Transfer Pricing Adjustment

February 14, 2024 852 Views 0 comment Print

ITAT Mumbai rules against penalty under Sec 271G for a diamond trader’s failure to provide segmental information, emphasizing substantial compliance.

ITAT Clears Transfer Pricing Battle for Boeing India

February 14, 2024 459 Views 0 comment Print

ITAT Delhi resolves Boeing India’s transfer pricing dispute, clearing an INR 21,52,899 adjustment tied to operational inactivity and a merger with BCIL.

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