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 : The Tribunal held that the Indian entity was only a distributor and not a technology or content owner. It rejected the Revenue’s...
Income Tax : This explains the new block assessment mechanism allowing ALP to apply across multiple years. It emphasizes reduced disputes and s...
Income Tax : The issue concerns replacement of Form 3CEB with a new reporting framework. The reform mandates structured reporting with enhanced...
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 issue was whether high-turnover companies can be compared with a smaller software service provider. The Tribunal held that com...
Income Tax : The Tribunal held that transfer pricing adjustment cannot survive without a final assessment order post-DRP directions. Repeating ...
Income Tax : The Tribunal held that subscription to preference shares cannot be re-characterized as loans in absence of evidence showing sham t...
Income Tax : The tribunal held that the safe harbour limit applies to valuation determined by the DVO, not just stamp duty value. It ruled in f...
Income Tax : The Court held that Tribunal remand is not a fresh reference under transfer pricing law. Hence, limitation expired earlier, entitl...
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...
In the recent past, Central Board of Direct Taxes (CBDT) has issued an instruction No. 3/2016 (Instruction) in perspective of the international transaction or specified domestic transactionto be referred by the Assessing Officer (AO) to Transfer Pricing Officer (TPO). The instruction ushered new guidelines for implementation of Transfer Pricing Provisions for referring international transactions or specified domestic transaction to the TPO subject to the approval of jurisdictional Principal Commissioner of Income Tax (PCIT) / Commissioner of Income Tax (CIT).
OECD stands for Organization for Economic Co-operation and Development. It is an international organization comprising of 34 countries with an objective to stimulate economic progress and world trade. The organization actively conducts researches in various areas of taxation and economic development based on which it issues recommendations to its member countries.
11/5/2016 – OECD countries agreed today to invite Latvia to become a member of the Organisation – a move that would extend OECD’s membership to 35 countries. OECD Secretary-General, Angel Gurría Said: “We are very pleased to welcome Latvia as a member of the OECD. This development reaffirms our Organisation’s commitment to bring together countries who […]
F.No. P-328/T&P/DC-ACsIT/2016-17/1818 OFFICE OF THE PRINCIPAL CHIEF COMMISSIONER OF INCOME TAX NEW DELHI Dated : 11th May, 2016 ORDER NO. 38/G.O. 2016-17 Sub:-Estt. Group ‘A’ – Transfers and Postings of Deputy/Assistant Commissioners of Income-tax – Reg. – The transfers and postings of the following Deputy/Assistant Commissioners of Income-tax are hereby ordered with immediate effect and […]
The objective of the BEPS Project is to close gaps in international tax rules, effectively eliminating or substantially reducing BEPS; and to secure government revenues by ensuring that profits are taxed in the jurisdiction where the economic activities generating such profits are performed and where value is created.
ITAT held that Revenue has not disputed the fact that effective rate of interest paid by assessee in India was 6.62% on loans whereas Interest paid by assessee on loans taken from AE abroad was 5%. This was below the rate of interest assessee was paying on loans taken within India.
Action plan on Base Erosion and Profit Shifting (‘BEPS’) issued by Organization for Economic Co-Operation and Development’s (‘OECD’) inter alia has proposed to levy a tax on digital transaction to equalize the tax burden on remote and domestic supplier of goods as well as services.
Delhi High Court held In the case of Honda Cars India Limited vs. DCIT that Since the petitioner is not an eligible assessee in terms of Section 144C(15)(b), no draft order can be passed in the case of the petitioner U/s. 144C(1). Section 144C (15)(b) of the Act defines an “eligible assessee”
Central Board of Direct Taxes signed 11 unilateral APAs on 28th March, 2016. With this signing, India has entered into 59 bilateral and/or unilateral APAs. 50 of these agreements have been signed in the current financial year. The agreements cover a range of international transactions, including corporate guarantees, royalty, software development services, IT enabled services and trading.
The finance bill 2016 has introduced three changes that has originated from the BEPS Action plan. What are these BEPS Action plan recommendations and what has it got to do with our Tax systems and economy?
