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 : The Tribunal restored the matter to the Assessing Officer after finding that transfer pricing adjustments may have been added twic...
Income Tax : ITAT Delhi held that television channel and content owner companies could not be compared with a content distribution business. Th...
Income Tax : ITAT Mumbai held that distribution fees paid to associated enterprises could not be treated as royalty. The Tribunal followed earl...
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 : 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...
CIT Vs Ut Starcom Inc. (India Branch) (Delhi High Court)- When we examine the profile of the assessee company vis-à-vis Infosys Technologies Limited in the light of the judgment in CIT vs. Agnity India Technologies Pvt. Ltd. (supra), there is no comparability for benchmarking the international transactions for the reasons inter alia that Infosys Technologies […]
Avenue Asia Advisors Pvt. Limited Vs. DCIT (Delhi High Court) Broadly, it appears that the ITAT has gone on the usage of several terms such as debt syndication, debt financing, IPO advisory, corporate restructuring, mergers, acquisitions etc, appearing in the annual reports of the comparable to hold that the Assessee and the said comparables perform similar functions.
As a measure of safeguard against base erosion and profit shifting (BEPS) by Multinational Enterprises (MNEs) and following the Action Plan 13 of OECD, of which the India is a member country, the amendment was made recently in the Income Tax Act mandating the maintenance and furnishing of Master File and filing of Country-by-Country Report (CbCR). The draft rules for public discussion relating to the said amendment were notified on 6th October 2017.
In this Article, author has provided his major observations from Draft Rules in respect of Master file, CBCR and Major requirements in Master file as per Draft Rules have been summarized.
It is proposed to insert rulac 10DA, 10DB and form nos. 3CEBA to 3CEBE in the Income-tax Rules, 1962 (`the Rules’), laying down the guidelines for maintaining and furnishing of transfer pricing documentation in the Master File and Country-by-Country report. In this regard, the following guidelines are proposed to be prescribed:
Transfer Pricing Regulations is an internationally accepted method to check that multinational enterprises entering into transactions with associated enterprises do not evade taxes by undervaluing the transaction. The purpose and ambit of Transfer Pricing Regulations is to ensure that international transactions between associated enterprises are computed having regard to the arm’s length price.
Section 92CB of the Income Tax Act 1961 provides that the determination of arm’s length price under Section 92C OR 92CA. However, same shall be subject to Safe Harbour Rules. Sections 10 TA to 10 TG deals with the Safe Harbour Rules, which pertain to International Transactions. Rule 10TE provides a detailed procedure for exercise […]
These rules may be called the Income-tax (21st Amendment) Rules, 2017.They shall come into force and shall be deemed to have come into force from the 1st day of April, 2017. In the Income-tax Rules, 1962, in Appendix II, in Form No. 3CEFA, in paragraph 2, under the heading Eligible International Transaction
The taxation regime in India seems to be undergoing crucial changes to negate the above quote from one of the greatest philosophers of all times. On this backdrop, the principles of thin capitalisation as prescribed in the Organization for Economic Cooperation and Development (‘OECD’) Base Erosion and Profit Shifting (‘BEPS) Action Plan 4 have prompted Indian lawmakers to adopt the same vide Finance Act, 2017.
The increase in globalization and technological advancement has resulted in the international expansion of several multinational and Indian corporations. Over the years, these corporations have used their global presence to enter low-tax jurisdictions, primarily to reduce the overall effective tax costs.
