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 : 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 : ITAT Ahmedabad held that transfer pricing authorities cannot assign a NIL arm’s length price when the assessee has demonstrated ...
Income Tax : The Hyderabad ITAT found contradictions in the TPO’s reasoning for excluding a comparable company due to alleged lack of RPT dat...
Income Tax : Pune ITAT held that once TNMM is accepted for a taxpayer’s aggregated international transactions, the TPO cannot isolate a singl...
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 Mumbai deleted the transfer pricing adjustment on management fees after finding that identical issues in the assessee’s own earlier years had already been decided in its favour. The Tribunal followed the principle of consistency.
The ITAT held that transfer pricing adjustment was not justified where the foreign LLC’s income was already offered to tax in India by the assessee. The Tribunal deleted the TP addition, finding no profit shifting or tax erosion.
ITAT Ahmedabad held that transfer pricing authorities cannot assign a NIL arm’s length price when the assessee has demonstrated actual receipt of intra-group services through supporting evidence.
The Hyderabad ITAT found contradictions in the TPO’s reasoning for excluding a comparable company due to alleged lack of RPT data. The Tribunal directed fresh verification and recomputation of the RPT filter before deciding whether the company should remain excluded.
Pune ITAT held that once TNMM is accepted for a taxpayer’s aggregated international transactions, the TPO cannot isolate a single transaction and apply a different method. The ruling deleted the transfer pricing adjustment and reinforced consistency in benchmarking.
ITAT Ahmedabad held that the Transfer Pricing Officer cannot determine the arm’s length price of intra-group services at Nil merely based on assumptions regarding benefit or commercial necessity.
The Bangalore ITAT upheld exclusion of manufacturing entities from transfer pricing comparables after finding that the assessee’s activities were mainly trading in nature. The Tribunal held that manufacturers and traders differ significantly in functions, assets, and risks.
Tribunal ruled that market value for captive power consumption must be based on the tariff charged to industrial consumers by TNEB while computing deduction under Section 80IA.
Tribunal directed inclusion of Cyber Media Research Limited after finding that market research and consultancy services were comparable to the assessee’s support service activities. Earlier Tribunal rulings supporting comparability were followed.
ITAT Delhi held that notional interest on business advances cannot be taxed without actual accrual or receipt of income. The Tribunal deleted the addition after finding that the advances were made during the ordinary course of business.
