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...
Mitchell Drilling India Private Limited vs. DCIT (ITAT Delhi) It is elementary that the ALP is determined of an `international transaction’, which has been defined in section 92B of the Act. The term `transaction’, for the purposes of the Chapter–X containing transfer pricing provisions, has been defined in clause (v) of section 92F to include an […]
Axis Risk Consulting Services Private Limited. Vs DCIT (ITAT Delhi) the only dispute before us is with regard to the adjustment by way of imputing interest @ 17.22% by the TPO on account of receivables from the AE. Here in this case, it is an undisputed fact that the assessee has also rendered similar services […]
The revised SHRs apply for AY 2017-18 and two immediately following AYs i.e. upto AY 2019-20. The earlier SHRs were applicable from AY 2013-14 and four immediately following AYs i.e. upto AY 2017-18. For AY 2017-18, the taxpayer can choose from old or new rules whichever are more beneficial.
Marketing activities undertaken by one enterprise not owning the trademark or brand name lead to the creation of marketing intangibles for the legal owner of such trademark or brand name. Indian enterprises having the right to use the brand name owned by their associated enterprises incurs the advertisement, marketing and promotional expenses (AMP Expenses) to get the benefit in the form of increased sales, higher profit etc. This in turns benefit the legal owner of the brand name i.e. associated enterprises.
Attached PPT Cover Following Topics related to Transfer Pricing : Basic Provisions, Issues and Latest Developments- ♥ Introduction to Transfer Pricing ♥ Transfer Pricing Regulations in India – Sec.92 to 92F ♥ Analysis of word “Income” as mentioned in Sec.92 ♥ AE & Deemed AE [Interplay between Sec.92A(1) & 92A(2)] ♥ International Transaction – Sec.92B […]
Hon’ble ITAT upheld the position of law as iterated by CIT (A) that it is an established law applicable for imposition of penalty that law, as in force, at the time of filing of Return would be applicable.
Margins derived on export of parts to AE are not comparable with the margins derived from sales made in the domestic market. Besides, on facts, it was also found that not only the parts and finished goods are not comparable, but the class of customers to whom they sold is also different.
Mehsana District Co-operative Vs. DCIT (Gujarat High Court) Subrule (7) of rule 10THD thus lays down the time limit for the Assessing Officer to pass an order under subrule(4) and for the concerned competent authority to pass an appropriate order under subrule(6). We may recall under subrule(4), the Assessing Officer may declare that the option […]
It is worthwhile to note that there are marked similarities between the Transfer pricing and Customs regulations in terms of the methodology to arrive at the relevant transfer price. For instance, the deductive method under Customs law can be correlated to the resale price method under Transfer Pricing law.
The Indian Central Board of Direct Taxes (CBDT) has notified the final rules (the rules) for maintaining and furnishing of Transfer Pricing (TP) documentation in the Master File (MF) and Country-by-Country Report (CbCR). Following an inclusive approach when introducing a new and important regulation, the CBDT had
