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 : The Tribunal held that the Indian entity was only a distributor and not a technology or content owner. It rejected the Revenue’s...
Income Tax : This explains the new block assessment mechanism allowing ALP to apply across multiple years. It emphasizes reduced disputes and s...
Income Tax : The issue concerns replacement of Form 3CEB with a new reporting framework. The reform mandates structured reporting with enhanced...
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 : The issue was whether high-turnover companies can be compared with a smaller software service provider. The Tribunal held that com...
Income Tax : The Tribunal held that transfer pricing adjustment cannot survive without a final assessment order post-DRP directions. Repeating ...
Income Tax : The Tribunal held that subscription to preference shares cannot be re-characterized as loans in absence of evidence showing sham t...
Income Tax : The tribunal held that the safe harbour limit applies to valuation determined by the DVO, not just stamp duty value. It ruled in f...
Income Tax : The Court held that Tribunal remand is not a fresh reference under transfer pricing law. Hence, limitation expired earlier, entitl...
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...
Delhi High Court held that tax authorities cannot replace projected business valuations with actual results when assessing transfer pricing, emphasizing commercial prudence principle in asset transfers.
Notification 157/2025 sets 1% tolerance for wholesale trading and 3% for all other cases for Arm’s Length Price variation for AY 2025-2026 under the Income-tax Act.
Tribunal held that Netflix India is a limited-risk distributor providing access support services, not a content or technology entrepreneur. Since no copyright or technical licence existed, the ₹445-crore royalty-based transfer pricing adjustment was deleted.
KSCAA urged CBDT to extend due dates for assessees under Section 92E, citing an omission in Circular No. 15/2025 that created inconsistency in tax compliance timelines.
Delhi HC reviews CBDT’s decision to exclude Transfer Pricing (TP) cases from the extended ITR deadline, an unprecedented departure from past practice. The case addresses the arbitrary denial of relief to TP-only assessees, raising concerns over administrative fairness and compliance consistency.
ejecting the Revenue’s approach, the Tribunal held that mere quantum of advertisement or marketing expenses cannot trigger transfer pricing adjustment without demonstrating a direct nexus with a foreign AE.
CBDT Circular extends ITR filing to Dec 10, 2025, and Audit Reports (44AB/12A) to Nov 10, 2025, for audit assessees. TP report deadlines are unchanged.
The CBDT extended the ITR deadline for audited cases (Oct 31 date) but excluded TP audit cases (Nov 30 date). This technical gap means TP deadlines may remain unchanged, requiring an urgent CBDT clarification.
ITAT rules LRD trading and after-sales services are functionally inseparable for TP. Mechanical segregation rejected; TNMM must be applied at the entity level on an aggregated basis.
The Karnataka High Court affirmed that SEZ units can claim Section 10AA deduction on income enhanced through a voluntary Advance Pricing Agreement (APA) adjustment. The ruling clarifies that the bar under Section 92C(4) applies only to income enhanced by the Assessing Officer, not to voluntary APA compliance.
