Income Tax : This article explains how Safe Harbour Rules under the Income-tax Act, 2025 interact with APAs, MAP provisions, and transfer prici...
Income Tax : The framework outlines mandatory disclosures and timelines for opting into safe harbour. Key takeaway: strict compliance is essent...
Income Tax : The article explains how safe harbour rules simplify transfer pricing compliance. It highlights that eligible transactions are acc...
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 : 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 : ITAT Mumbai deleted the transfer pricing adjustment on management fees after finding that identical issues in the assessee’s own...
Income Tax : The ITAT held that transfer pricing adjustment was not justified where the foreign LLC’s income was already offered to tax in In...
Income Tax : ITAT Ahmedabad held that transfer pricing authorities cannot assign a NIL arm’s length price when the assessee has demonstrated ...
Income Tax : The Hyderabad ITAT found contradictions in the TPO’s reasoning for excluding a comparable company due to alleged lack of RPT dat...
Income Tax : Pune ITAT held that once TNMM is accepted for a taxpayer’s aggregated international transactions, the TPO cannot isolate a singl...
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...
Courts have ruled that references to the TPO cannot be made mechanically. The key takeaway is strict compliance with CBDT Instruction No. 3/2016 is mandatory for jurisdiction.
The High Court held that issuing a draft assessment order under Section 144C is invalid where the Transfer Pricing Officer proposes no variation. The key takeaway is that absence of TP adjustment means the assessee is not an “eligible assessee,” making DRP proceedings without jurisdiction.
The Tribunal ruled that inclusion of giant companies distorted arm’s length results for a small captive service provider. High-turnover companies were excluded to ensure meaningful comparability.
The Tribunal held that mere facilitation of third-party payments to an associated enterprise does not constitute a service. As no value addition was involved, applying a markup on reimbursements was found unsustainable.
The Delhi High Court upheld exclusion of multiple comparables after finding them functionally different from a low-risk investment advisory service provider. It held that such findings were factual and did not raise any substantial question of law.
The Tribunal ruled that high-turnover IT companies cannot be benchmarked against smaller captive service providers. Proper FAR analysis is essential to determine arm’s length price under TNMM.
Tribunal held that a company engaged in diversified IT consultancy and transformation services cannot be compared with a routine software development service provider
The Tribunal held that advances linked to regular business dealings such as sale of timeshare weeks cannot be taxed as deemed dividend, reaffirming that commercial transactions fall outside section 2(22)(e)
The ruling set aside a large AMP adjustment after finding that commission paid to distributors could not be recharacterized as marketing expenditure. Consistency with prior years played a decisive role in deleting the adjustment.
The issue was whether the Assessing Officer could alter income despite a valid APA and modified return. The Court held that without an adverse TPO audit or APA cancellation, reassessment adjustments were without jurisdiction.
