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Income Tax : ICAI Releases Exposure Draft Guidance Note On Report Under Section 92E Of Income-Tax Act, 1961 (Transfer Pricing) Based on the la...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 : Delhi High Court held that Resale Price Method (RPM) is the most appropriate method to determine arm’s length price since assess...
Income Tax : Delhi High Court held that before undertaking a benchmarking of Advertisement, Marketing and Promotion [AMP expenses], it was incu...
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 : 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 Pune held In the case of M/s. Vishay Components India Pvt. Ltd. vs. ACIT that where the revenue from year to year has accepted the method adopted by the assessee for benchmarking its international transactions with its associate enterprises, in the absence of any reasons brought
In case of M/s. AT & T Global Business Services India Pvt.Ltd. VS. ITO , assessee-company, engaged in business of software development and providing application services to its AE. TPO on basis of mean margin earned by his own set of comparables
In the case of Rampgreen Solutions Pvt Ltd vs CIT, Delhi High Court inter-alia held that the expression ‘BPO’ and ‘KPO’ are, plainly, understood in the sense that whereas, BPO does not necessarily involve advanced skills
In the case of Venture Infogain India Pvt. Ltd vs. Dy.Commissioner of Income Tax ITAT has held that provisions the Profit Split Method is applicable mainly in international transactions which are so interrelated that they cannot be evaluated separately
The purpose of a benchmarking study is to select comparable transactions by rationally deriving arm’s length price based on the financial data of selected comparable. On one side the comparables selected by assesses are rejected in many cases particularly of loss making companies and on the other hand high margin comparables are cherry picked and applied.
ITAT Delhi held in the case American Express (India) Private Limited vs. DCIT that even though the assessee in its TP study has included the turnover filter of less than Rs.1 crore, the assessee has given reasons for inclusion of these two companies in the list of comparables
In the case of Price Waterhouse & Anr. Vs CIT, Calcutta High Court through an interim order opined that if there was no relevant material in the hands of the Income Tax authorities with which it has come to an incontrovertible conclusion that the writ petitioner no.1 was an ‘associated enterprise’
ITAT Hyderabad held In the case of M/s. OSI Systems Pvt. Ltd. vs. DCIT that it may be a fact that software development services is a very wide term and takes within its ambit, whole software development services.
ITAT Jaipur held In the case of M/s. Gillette India Ltd. vs. ACIT that the services availed are intra-group services in the nature of Accounting and Financial Reporting Services, Employee services etc. . These are routinely outsourced by no. of companies in India and other countries because of their economic
In the case of HCL Technologies BPO Services Ltd vs. ACIT, ITAT has held that for transfer pricing only amount retained by associates from end user is to be taken into account for transfer pricing adjustment, and to adjust operating cost by excluding abnormal cost incurred on a/c of Startup Company like salary, rent, and depreciation.
