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 this case, the ITAT ruled that extended credit period allowed to the Associated Enterprises (‘AE’) amounted to short term funding without interest and thus attracted TP adjustment on account of notional interest from such short term funding.
The issue is no longer res integra as it has been decided by Hon’ble ITAT Banglore in case of M/s Yahoo Software Development India Pvt Ltd vs DCIT (ITA No. 1129/Bang/2010) pronounced on 31st December 2014. In the instant case, the Assessee filed an appeal against the order of the Learned AO and pleaded that
On 19.12.2014, Central Board of Direct Taxes has signed a bilateral Advance Pricing Agreement (APA) with a Japanese Company. This is India’s first bilateral APA. The APA is for a period of five years. The APA has been finalized in a period of about one and a half years, which is shorter than time normally taken in finalizing APAs internationally.
What is BEPS -BEPS refers to tax planning strategies that exploit gaps and mismatches in tax rules to artificially shift profits to low or no-tax locations where there is little or no economic activity, resulting in little or no overall corporate tax being paid.
In the Judgment of Aurionpro Solutions Ltd. vs. ACIT, Range – 4(3), Mumbai, ITA No. 7872 (Mum.) of 2011, ITAT Mumbai has held that for purpose of determination of Arm’s Length Price, tested party is always assessee and not its Associate Enterprise (AE), LIBOR is acceptable for benchmarking loans given by Indian company to its foreign AEs, instead of interest rates prevailing in India.
Comment on Shell’s wins of transfer pricing tax dispute in Bombay HC The aggressive approach of tax authorities and the earlier government in case of Vodafone and Shell led to erosion of confidence of global investors. In this context, the favourable decision of H’ble Bombay High Court in case of Shell India Markets Private Limited […]
Neither the capital receipts received by the Petitioner on issue of equity shares to its holding company, a non-resident entity, nor the alleged short-fall between the so called fair market price of its equity shares and the issue price of the equity shares can be considered as income within the meaning of the expression as defined under the Act.
Contemporaneous documentation means information, records and other documents which exist or brought into existence at the time the taxpayer is developing or implementing any arrangement that might raise transfer pricing issues. It is important that documentation on which assessee is placing reliance to establish arm’s length price should be the one which was available when […]
In the instant case, the assesse has issued shares to its holding company at premium (INR 8591) amounting to INR 246.38 crores. The said transaction was reported in Form 3CEB, although assesse claimed TP Provisions are not applicable on income arising on such transactions.
Notification No. 45/2014-Income Tax DATED 23-9-2014 Central Government hereby notifies that where the variation between the arm’s length price determined under section 92C and the price of which the international transaction or specified domestic transaction has actually been undertaken does not exceed one percent of the latter in respect of wholesale trading and three percent of the latter.
