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Transfer Pricing

Latest Articles


Future of International Taxation: OECD Global Minimum Tax

Income Tax : Learn about income tax exemptions for universities, hospitals, and educational institutions under Section 10 of the Income Tax Act...

March 11, 2025 525 Views 0 comment Print

Budget 2025: Transfer Pricing Amendments

Income Tax : Learn about the amendments to Section 92CA concerning references to the Transfer Pricing Officer for determining arm's length pric...

February 4, 2025 1206 Views 0 comment Print

Transfer Pricing Amendments: Multi-Year ALP Determination

Income Tax : New transfer pricing rules allow arm’s length price (ALP) determinations to apply for two consecutive years, reducing compliance...

February 3, 2025 810 Views 0 comment Print

Transfer Pricing: Multi-Year ALP Determination in Budget 2025 – FAQs

Income Tax : Finance Bill 2025 allows multi-year Arm’s Length Price determination for similar transactions, reducing repetitive proceedings i...

February 2, 2025 612 Views 0 comment Print

Finance Bill 2025: Amendment related to Transfer Pricing

Finance : The Finance Bill 2025 proposes multi-year ALP determination to reduce compliance burdens in transfer pricing. Learn about its fram...

February 1, 2025 1272 Views 0 comment Print


Latest News


Tolerance Range for Transfer Pricing Notified for AY 2024-25

Income Tax : CBDT sets transfer pricing tolerance range at 1% for wholesale trading and 3% for other transactions for AY 2024-25, providing cla...

October 30, 2024 1020 Views 0 comment Print

Budget 2024: TPO can evaluate SDTs not reported by taxpayers

Income Tax : From April 2025, TPOs can determine ALP for SDTs not initially referred or reported. This ensures accurate adjustments and complia...

July 26, 2024 516 Views 0 comment Print

FAQ’s on filing of Income Tax Form 3CEB

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...

October 28, 2022 13632 Views 0 comment Print

Draft Guidance Note on Transfer Pricing Report – Section 92E

Income Tax : ICAI Releases Exposure Draft Guidance Note On Report Under Section 92E Of Income-Tax Act, 1961 (Transfer Pricing) Based on the la...

July 21, 2022 26145 Views 1 comment Print

ACAE Requested due date extension for filing Tax & TP Audit

Income Tax : Association for Corporate Advisers and Executives (ACAE) made a Request for Extension of Due Dates for filing Tax Audit and Transf...

January 7, 2022 11808 Views 1 comment Print


Latest Judiciary


Cost Allocation and Transfer Pricing – ITAT Bangalore Ruling

Income Tax : Advocate Amardeep Soni & Advocate Harsha Soni Gemplus India Pvt. Ltd. Vs ACIT (ITAT Bangalore) A Case Study of ITAT BANGALORE...

March 19, 2025 306 Views 0 comment Print

Fresh Adjudication Ordered on TPO Adjustment in Subsidiary Transaction

Income Tax : Bangalore ITAT overturns AO's PE classification of QlikTech India, orders fresh review based on TPO order, addresses TDS and inter...

March 9, 2025 78 Views 0 comment Print

Indian Subsidiary Not a Dependent Agency PE if Transactions Are Subject to TPO Adjustment

Income Tax : ITAT Bangalore sets aside AO's decision in Qlik Tech International AB vs DCIT, addressing PE classification, TDS credit, and tax r...

March 8, 2025 156 Views 0 comment Print

Comparable cannot be excluded in Absence of Persistent Losses: ITAT Delhi

Income Tax : ITAT Delhi directs inclusion of Magma Advisory Services Ltd. in Honda R&D's comparable list, rejecting TPO's reasons and DR's func...

February 28, 2025 168 Views 0 comment Print

Protective Addition Unsustainable if Substantial Addition is Confirmed or Settled: ITAT Bangalore

Income Tax : ITAT Bangalore deletes AO’s protective addition in LM Wind Power case, citing settled MAP proceedings on IT fees and commission ...

February 27, 2025 198 Views 0 comment Print


Latest Notifications


Tolerance Range for Arm’s Length Price in FY 2024-25

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...

October 18, 2024 1395 Views 0 comment Print

Income-tax (Twenty-Ninth Amendment) Rules, 2023

Income Tax : Stay informed on the latest Income Tax Rule changes with Notification No. 104/2023 by the Ministry of Finance. Learn about amendme...

December 19, 2023 3723 Views 0 comment Print

CBDT extends applicability of Safe Harbour rules to AY 2023-24

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...

August 9, 2023 11955 Views 0 comment Print

Deemed Arm’s Length Price for Assessment Year 2023-2024

Income Tax : Notification No. 46/2023-Income-Tax Dated: 26th June, 2023  regarding deemed arm's length price for assessment year 2023-2024. Le...

June 26, 2023 1737 Views 0 comment Print

Tolerance Band for AY 2022-23 in case of wholesale trading & others

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...

June 28, 2022 2646 Views 0 comment Print


Errors in selection of comparables: ITAT Delhi Remits Matter back to TPO/AO

February 9, 2024 492 Views 0 comment Print

In the case of American Express Services India Ltd. Vs DCIT, Delhi ITAT remits the matter for correct market segment selection, following earlier order. Full text of the ITAT Delhi order included.

Transfer Pricing-Traditional Transaction Methods: Cost Plus Method 

February 2, 2024 2688 Views 0 comment Print

Explore the Cost Plus Method for transfer pricing. Learn its application, methodology, and key considerations. Navigate complexities with practical examples.

Resale Price Method (RPM) in Transfer Pricing: Analysis 

February 1, 2024 6207 Views 0 comment Print

Explore the intricacies of Resale Price Method (RPM) in transfer pricing. Understand its components, implementation steps, and real-world applications. Dive into case examples highlighting strengths, weaknesses, and considerations for reliable comparisons

Overview of Transactional Net Margin Method (TNMM) – Part I

January 25, 2024 7053 Views 0 comment Print

This section delves into transactional profit methods, which serve to analyze the profits derived from specific controlled transactions to ascertain if the transfer price aligns with arm’s length principles. Within this category, two primary methods are discussed: the Transactional Net Margin Method (TNMM) and the Profit Split Method (PSM). 

Delhi HC remits ALP Determination Method matter to CIT(A)

January 21, 2024 291 Views 0 comment Print

Explore the judgment in Bombardier Transportation India Pvt. Ltd. Vs DCIT by Delhi High Court. The court remits the matter for determining the Arm’s Length Price (ALP) method.

Overview of Comparable Uncontrolled Price (CUP) Method in Transfer Pricing

January 21, 2024 7062 Views 0 comment Print

Explore the Comparable Uncontrolled Price (CUP) method in transfer pricing – its methodology, application, benefits, risks, case study, and insights on when to use. Learn more!

Thin Cap Adjustment Provisions Under Section 94B

January 20, 2024 8676 Views 2 comments Print

Explore the Thin Cap Adjustment Provisions under Section 94B of the Income Tax Act, addressing base erosion and profit shifting. Learn about its impact on NBFCs, start-ups, and global approaches.

Delhi High Court Upholds 15% Attribution Rate for Travelport

January 19, 2024 546 Views 0 comment Print

Delhi HC upholds 15% attribution rate of revenue for Indian operations of Permanent Establishment based on gross booking by Travelport Global Distribution Systems B.V.

Delhi HC Upholds ITAT Order Excluding Comparables Due to Functional Dissimilarity

January 19, 2024 492 Views 0 comment Print

Delhi High Court upholds ITAT’s decision to exclude comparables Accentia, Eclerx, Mold-Tek, and TSR in the PCIT vs. Honeywell International transfer pricing case.

Summary of Hon’ble ITAT Pune decision on Transfer Pricing in the year 2023

January 9, 2024 1668 Views 0 comment Print

Explore detailed analysis of Hon’ble ITAT Pune decisions in 2023 on transfer pricing, covering allocation of expenses, custom duty, working capital, methods, and more.

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