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Income Tax : ICAI Releases Exposure Draft Guidance Note On Report Under Section 92E Of Income-Tax Act, 1961 (Transfer Pricing) Based on the la...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 : 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 : ITAT Delhi clarifies tax treatment for Motricity India: No levy on notional income or closure costs. Insights on Transfer Pricing ...
Income Tax : Karnataka HC decision on transfer pricing adjustments and Section 92BA amendments in the PCIT vs TT Steel Service India Pvt. Ltd. ...
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...
In the case of American Express Services India Ltd. Vs DCIT, Delhi ITAT remits the matter for correct market segment selection, following earlier order. Full text of the ITAT Delhi order included.
Explore the Cost Plus Method for transfer pricing. Learn its application, methodology, and key considerations. Navigate complexities with practical examples.
Explore the intricacies of Resale Price Method (RPM) in transfer pricing. Understand its components, implementation steps, and real-world applications. Dive into case examples highlighting strengths, weaknesses, and considerations for reliable comparisons
This section delves into transactional profit methods, which serve to analyze the profits derived from specific controlled transactions to ascertain if the transfer price aligns with arm’s length principles. Within this category, two primary methods are discussed: the Transactional Net Margin Method (TNMM) and the Profit Split Method (PSM).
Explore the judgment in Bombardier Transportation India Pvt. Ltd. Vs DCIT by Delhi High Court. The court remits the matter for determining the Arm’s Length Price (ALP) method.
Explore the Comparable Uncontrolled Price (CUP) method in transfer pricing – its methodology, application, benefits, risks, case study, and insights on when to use. Learn more!
Explore the Thin Cap Adjustment Provisions under Section 94B of the Income Tax Act, addressing base erosion and profit shifting. Learn about its impact on NBFCs, start-ups, and global approaches.
Delhi HC upholds 15% attribution rate of revenue for Indian operations of Permanent Establishment based on gross booking by Travelport Global Distribution Systems B.V.
Delhi High Court upholds ITAT’s decision to exclude comparables Accentia, Eclerx, Mold-Tek, and TSR in the PCIT vs. Honeywell International transfer pricing case.
Explore detailed analysis of Hon’ble ITAT Pune decisions in 2023 on transfer pricing, covering allocation of expenses, custom duty, working capital, methods, and more.
