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...
Assessee was engaged in the field of providing insurance & Human Resources services to its associated enterprise in UK. The Ld. AO /TPO made an addition to the income of the assessee by comparing the income of the assessee with the income of the comparable companies
In the present facts of the case the Hon’ble High Court held that as the assessee have not taken substantial risks and was a mediator in the international transactions. Hence, Transactional Net Margin Method is a right method instead of Profit Split method.
Transfer Pricing is the setting of the price for goods and services sold between controlled/related legal entities. It is generally aimed at depicting favourable performance of a conglomerate by shifting earnings from a high tax jurisdiction to a low-tax one.
Whether the transactions between the head office in India and branch office in Canada can be considered as international transactions? The assessee had entered into certain transaction with his branch office in Canada. The AO had taken these transactions also into sweep for the purposes of making the transfer pricing adjustment.
The Tribunal, in assessment year 2006-07, in the assessee’s own case and on identical facts/ circumstances, has given a clear finding that the fee received by the assessee for providing marketing and liasioning services cannot be equated with the advisory services given to an investment manager.
In the present case the Hon’ble Tribunal held that assessee can’t be compared with other companies when they are totally different in functions. Also, the Intellectual property Rights, Brand Value have to be seen while making comparisons under Transfer Pricing.
In An increasingly interconnected world, national tax laws have not kept pace with global corporations, fluid capital, and the digital economy thereby leaving gaps that can be exploited by companies who avoid taxation in their home countries by pushing activities abroad to low or no tax jurisdictions.
ITAT Licknow in the case of ACIT vs. M/s Rahman Industries Ltd. held that- Adjustment for variation in closing stock is necessary for the correct computation of Operating cost thereby correct application of Transaction Net Margin Method (TNMM).
Punjab & Haryana High Court held in CIT Vs DSM Anti Infectives India ltd that the benchmark comparable which was used to compare with the comparable company that should be considered only of that year of which TP case was involved.
Punjab & Haryana High Court held In the case of CIT vs. M/s DSM Anti Infectives India Ltd. that the filter used by the TPO while selecting comparable is to select companies who are using Penicillin-G as raw material irrespective of the extent of usage of the same.
