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...
ITAT Bangalore held In the case of DCIT vs. M/s. Parametric Technology (India) Pvt. Ltd. that the use of current year’s data is mandated by the relevant I.T. Rules, 1962 and by not adhering to this, the assessee’s TP Study was rendered unreliable.
In this case of Trend Micro India Pvt. Ltd. Vs. DCIT Delhi Bench of ITAT observed that whether revenue can argue against the order passed by AO in pursuance to the directions of DRP. The ITAT held that it is not permissible to argue any issue decided by AO by DR before tribunal.
ITAT held in Acclaris Business Solutions Lvt Ltd. Vs I.T.O that only those companies could be compared for calculating ALP which were functionally similar. Those companies which were not performing similar functions could not be compared for calculating ALP.
ITAT held in Haier Appliances India Ltd Vs DCIT and Haier Appliances India Ltd Vs ACIT after relying on the case of Sony Ericsson Mobile Communications India Pvt Ltd reported in (2015) 374 ITR 118 (Delhi) that the above transaction of AMP
CIT Vs. V/s. M/s. Thyssen Krupp Industries India Pvt. Ltd. (Bombay High Court) In terms of Chapter X of the Act, redetermination of the consideration is to be done only with regard to income arising from International Transactions on determination of ALP.
CIT Vs. V/s. M/s. Thyssen Krupp Industries India Pvt. Ltd. (Bombay High Court) Whether on the facts and the circumstance of the case and law, the Tribunal was justified in law in restricting the Transfer Pricing (TP) adjustment only to the transaction between the Associated Enterprises (AEs.)?
ITAT Bangalore held In the case of M/s. Meritor LVS India (P) Ltd. vs. ACIT that the transfer pricing officer (TPO) has drawn conclusions on the basis of information obtained by issue of notice u/s.133(6) .This information which was not available in public domain could not have been used by the TPO,
ITAT Delhi held In the case of Xchanging Technology Services India Private Limited. vs, DCIT that the Hon’ble High Court affirmed the conclusion that a captive unit of a comparable company which assumed only a limited risk cannot be compared with a giant company in the area of development
ITAT Delhi held In the case of Honda Trading Corporation. vs, DCIT that despite the use of the word `may’, the time limit for passing the order by the TPO is mandatory, as in the otherwise situation of the TPO having been allowed more time by implication
ITAT Delhi held In the case of Alcatel-Lucent Technologies. vs, DCIT that merely because the assessee in the TP study had included the comparable, which was accepted by TPO, it does not follow that the assessee cannot resile from its original claim at a later stage of proceeding
