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...
Finance : The Finance Bill 2025 proposes multi-year ALP determination to reduce compliance burdens in transfer pricing. Learn about its fram...
Income Tax : Karnataka HC ruled that omission of Section 92BA(i) invalidates its application to domestic transactions, limiting transfer pricin...
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Income Tax : ICAI Releases Exposure Draft Guidance Note On Report Under Section 92E Of Income-Tax Act, 1961 (Transfer Pricing) Based on the la...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 : ITAT Bangalore remands case for a fresh TP study, directing TPO to assess the applicability of MAP-determined ALP to transactions ...
Income Tax : It was held that transactions and FAR of assessee were similar to AY 2021-22 and as per the records brought to our notice, there...
Income Tax : Respondent/assessee is a Irish company. It accordingly claimed benefits of the India-Ireland DTAA. ADIR is a wholly owned subsidia...
Income Tax : In the matter above-mentioned ITAT partly allowed the appeal filed by the assessee by remanded it back to file of TPO after consid...
Corporate Law : Delhi HC rules that SEB rates, not IEX rates, determine the market price of electricity in transfer pricing cases, dismissing Reve...
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...
Income Tax : In exercise of the powers conferred by the third proviso to sub-section (2) of section 92C of the Income-tax Act, 1961 (43 of 1961...
It is a common case that Satyam Computer Services Ltd. should not be taken into consideration. The tribunal for valid and good reasons has pointed out that Infosys Technologies Ltd. cannot be taken as a comparable in the present case.
This public discussion draft includes proposals for additions and changes to the Commentary on the OECD Model Tax Convention resulting from the work of that subgroup. These proposals have recently been presented to the Working Party for discussion with a view to their possible inclusion in the OECD Model Tax Convention.
The arm’s length result under the TNMM is determined to the net profit margin of a comparable transactions under a comparable circumstances and the profitability derived from uncontrolled party engaged in similar business activity under similar circumstances are to be analysed.
In the last few years the Government of India has taken many steps in order to strengthen the Transfer Pricing (Taxation) regime in India. A series of amendment has been introduced in order to enhance the ambit of tax base and consequent increase in the revenue. The latest step in this direction was the extension […]
Chapter X of the Income-tax Act, 1961 contains special provisions relating to avoidance of tax. Terms such as ‘associated enterprise’, ‘international transaction’, ‘intangible property’, and ‘specified domestic transaction’ are defined in different sections of the Chapter.
The Committee set-up by the Government to examine some of the issues relating to taxation of income of persons engaged in the IT sector is glad to furnish its first report on some of these issues. Its report on the other issues will follow in due course. While furnishing this report, I must duly acknowledge […]
In pursuance of the changes made by the Finance Bill 2012 bringing specified domestic transactions under the ambit of Transfer Pricing Regulations, CBDT has amended the format of Form 3CEB vide notification number 41 dated 10 June 2013. The said notification also amends Rule 10A, 10AB, 10B, 10C, 10D and 10E.
The Finance Act’ 2012 has introduced Section – 92 CD relating to the Advance Pricing Agreement (APA) which came into force w.e.f. 1st July’ 2012. An Advance Pricing Agreement is an agreement between the taxpayer and the tax authority on the pricing of future related party transactions. The Taxpayer and the tax authority agrees on […]
Notification No. 41/2013 – Income Tax The CBDT has notified vide Notification No. 41 dated 10 June 2013, new Form 3CEB which includes reporting on specified domestic transactions. The said notification also amends Rule 10A, 10AB, 10B, 10C, 10D and 10E. Following are the additional international transactions required to be reported in new Form 3CEB: International transaction(s) in the nature of guarantee
The Transfer Pricing provisions has been introduced in india in the year 2001. Since then it has come a long way. Now, the Finance Act’ 2012 has extended the scope of Transfer Pricing provisions to certain specified domestic transactions and introduced section-92BA in order to bring in certain specified domestic transactions undertaken by the enterprises […]
