Transfer Pricing

  • ICAI

ICAI Revised Guidance Note on Transfer Pricing Report u/s 92E of Income-Tax Act. 2020 Edition

ICAI Revised Guidance Note on Transfer Pricing Report Under Section 92E of the Income-Tax Act 1961 based on law as…

4 years ago
  • Income Tax

ALP determined in good faith & with due diligence by assessee not liable to penalty u/s 271(1)(c)

ALP determined in good faith and with due diligence by assessee was not liable to penalty u/s 271(1)(c) ABCAUS Case…

4 years ago
  • Income Tax

Guarantee not an international transaction u/s 92B of the Income Tax Act – ITAT

Guarantee does not amount to an international transaction under section 92B of the Income Tax Act. ITAT ABCAUS Case Law…

5 years ago
  • Income Tax

CBDT notifies tolerance range in transfer pricing for variation between arm’s length price u/s 92C

CBDT notifies tolerance range for wholesale trading and other cases for transfer pricing for variation between arm’s length price u/s…

5 years ago
  • Income Tax

Transfer pricing adjustment without TPO reference. AO breached mandatory CBDT Instruction – SC

Transfer pricing adjustment without reference to TPO. Supreme Court upholds that AO breached mandatory Instruction but restored appeal to AO…

5 years ago
  • Income Tax

Non profit company not a comparable to benchmark international transaction under Transfer Pricing

Non profit company not a comparable for Transfer Pricing. ITAT directed AO to exclude it from the list of comparables…

5 years ago
  • Income Tax

Arm’s length rate of interest is the rate prevalent in country of AEs not advancing enterprise

Arm’s length rate of interest is the rate prevalent in country of AEs where loan is received/consumed and not the…

5 years ago
  • Income Tax

AO not required to issue draft rectification order for assessment completed u/s 144C

AO not required to issue draft rectification order for assessment completed u/s 144C. Only a proposed “order of assessment” can…

5 years ago
  • Income Tax

Draft Assessment order u/s 144C with demand and penalty notice is illegal

Draft Assessment order u/s 144C with demand and penalty notice  is illegal as it partakes the character of final assessment…

5 years ago
  • Income Tax

Arms Length Price of management fee paid determined Nil by TPO upheld

Arms Length Price of intra group management fee paid determined Nil by TPO upheld as there was no evidence on…

5 years ago