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Flash

Key Highlights of the US Supreme Court judgment striking down Trump Tariffs

CBDT publishes draft Income tax Rules & Forms for New Income tax Act

CBDT issues detailed FAQs on Budget 2026

Copy of Finance Bill and Memorandum to Finance Bill, 2026

Buy backs to be taxed as capital gains for non-promoters

Economic Survey 2025–26 highlights deeper Tax Base, calls for TP-Customs convergence

Copy of Economic Survey 2025-26 tabled before the Parliament today

ITAT: Rejects recharacterisation of Netflix India as full-fledged entrepreneur or content-provider; Deletes Rs.445 Cr adjustment

New Income-tax Bill, 2025 receives President's assent

Lok Sabha passes The Taxation Laws (Amendment) Bill, 2025

First on Taxsutra

Search Judgment Aftermath - Revenue seeks SC's clarification vis-a-vis Sec.148 proceedings

First on Taxsutra

SC holds 'substantial question of law' lies before HC on comparable selection & ALP…

First on Taxsutra

SC decisively sets aside/reverses Karnataka HC judgment on comparables matter, allows Revenue appeal…

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Adjustments
- Accounting Policies
- Capacity
- Credit period
- Depreciation
- Others
- Risk
- Working Capital
ALP computation
- Arithmetic Mean - Arms Length range
- Benefit of +/- 5%
- Berry Ratio
- Entity level v. transaction level
- Margin computation dispute
- Operating/Non operating Income and Expenses
  - Foreign exchange gain / loss
- Pass through costs
- Profit level indicator (eg sales or costs)
  - Cash PLI
- Segmental results
- Single Year vs Multiple Year
- Suomoto adjustment by assessee
Appellate Authority - Powers, Jurisdiction etc.
- Admission of additional evidence
- Admission of additional ground
- DRP / CIT(A) order binding on AO
- Miscellaneous Application / Miscellaneous Petition
- Non-speaking DRP/ CIT(A) orders
- Power to remand matter back to AO/TPO
- Scope and powers
Appellate Authority - Powers, Jurisdiction etc.
Applicability of TP-provisions to income covered under the Tonnage Tax Scheme
Arms length principle under tax holiday provisions
Benchmarking
- Availability of Data
- Captive service provider
- Companies held to be functionally similar
- Concept of 'tested party'
- Controlled transaction as comparable
- Domestic and International transactions
- Filters
  - Bad debts filter
  - Employee cost
  - Financial year
  - Foreign exchange earnings
  - Onsite vs. Offshore Revenue Filter
  - Other filters
  - R&D filter
  - Related party transaction
  - Turnover
- Foreign comparables
- Functional similarity / dissimilarity
  - Exclusion of comparable due to unreliable financial results
  - Fluctuations in profit margins & comparability
  - Govt. owned undertakings
  - High end services vis--vis Low end services
  - High end services vis-à-vis Low end services
  - Impact on comparability of events like merger, acquisition, spin off
  - KPO vs BPO
  - Loss Making comparables
  - Outsourcing of work
  - Ownership of Intangible & comparability
  - Relevance of product similarity for comparability
  - Secret comparables
  - Software product companies vs. Software service companies
  - Super normal profit comparables
- Industry Rates
- Internal vs. External comparables
- Location Saving / Locational Advantage
- Relevance of FAR
- Reliance on Government Guidelines (RBI, FIPB, Commerce Ministry Press Notes, etc)
- Rulings having discussion on comparability of specific companies
- Separate and combined transactions
- Updation of comparables
- Use of Customs Data
Chapter X applicability
Commercial expediency
Concept of tested party
COVID-19
Definitions
- Associated Enterprise
- International Transaction
Delayed pronouncement of order due to Covid-19 lockdown
DIN on departmental communication
Domestic TP (Pre 2012 period)
E-assessment
Functional Classification
- Contract Manufacturing
- Contract R&D
- Distributor
- Retail traders
- Sogo shosha (acting as trading intermediaries)
Functional similarity or dissimilarity
Functional similarity/ dissimilarity
International transactions
- Commission
- Cost Allocations
- Cost Sharing Arrangements
- Deemed International transactions
- Employee Stock Option Plans
- Guarantee
- Intangibles - Trademarks, Copyrights, etc.
- Inter-company balance receivables
- Interest
  - FCCD Interest
- Issue of shares
- Loan
- Management Charges
- Marketing intangible/ AMP adjustment
  - AMP-Intensity Adjustment
- Other intra-group services
- Profits attributable to PE
- Provision of Freight forwarding/ Logistics services
- Provision of Information Technology Enabled Services (ITeS)
- Provision of Investment advisory services
- Provision of marketing support services
- Provision of software development service
- Purchase of fixed asset
- Reimbursements
- Royalty
- Sale of Shares
- Transfer of business to AE
- Treatment of CCD/FCCD/OFCD
- Treatment of share application money as loan
Methods
- Comparable Uncontrolled Price Method (CUP)
- Cost Plus Method
- Cost Plus Method more appropriate than TNMM
- CUP more appropriate than TNMM
- Profit Split Method
- Resale Price Method
- Ruling relevant for other method (6th method)
- TNMM more appropriate than CUP
- Transaction Net Margin Method
- Transactional Net Margin Method
Opportunity of being heard
Other
Penalty
- Concealment Penalty
- Penalty for non-filing / delay in filing particulars, audit report
Powers / Jurisdiction of Appellate Authority
- Condonation of delay
Provision of Business Support Services
Provision of software development services
Reference to Safe Harbour Rules
Rulings having discussion on comparability of specific comparables
shareholder services
Specified domestic transaction (SDT)
Substantial question of law on comparables
TNMM
TP adjustment & MAT provisions
Transfer pricing
Transfer Pricing applicability
- Base erosion plea u/s 92(3)
- Pre-2002 provisions
- Pre-condition for invoking Chapter X & Intent
- Reference to TPO
- TP applicability & existence of income/ taxable income
Transfer Pricing assessments
- Aggregation of Transactions
- assessment post merger/amalgamation
- Consideration of APA/MAP
- Final assessment without draft order
- Granting opportunity of being heard
- Miscellenous petition / application
- Powers / Jurisdiction of Assessing Authorities
  - Adjustments by TPO on issues not referred by AO
  - Questioning commercial expediency / Proving Benefit test
  - TPOs order binding on AO
- Reassessment u/s 147 in reference to transfer pricing provisions
- Relevance of International Material (OECD Guidelines, International case laws)
  - Reference to BEPS Action Plans
- Remand for fresh consideration
- Resolution under MAP/APA
- Retraction of comparables
- Revision u/s 263 w.r.t transfer pricing
- Right of assessee to seek correction of own mistakes
- Right to contest comparable when not contested before earlier forum
- Rule of Consistency
- Secondary adjustment
- Stay of demand
- Threshold limit of Rs 5 crores
- Time limit for completing the assessment
- TP and Search Proceedings

Number

Applevel

Year

Rulings

Income tax Appellate Tribunal Latest

ITAT: Upholds revision order u/s.263 for GMR Airports, TPO failed to enquire into SBLC arrangements

Mar 02, 2026

Income tax Appellate Tribunal

ITAT: Accepts berry ratio for Verizon India, restricts TP-adjustment w.r.t business services basis agreed…

Mar 02, 2026

High Court

HC: Quashes reassessment, Revenue failed to finalize assessment timely after draft order was passed

Feb 26, 2026

Income tax Appellate Tribunal

ITAT: Rejects foreign AE as tested party; Deletes adjustments qua interest on capital contribution, loan,…

Feb 24, 2026

Trending Topics :

Income Tax Bill, 2025
Trump Tariffs
Union Budget 2025
TOLA
GAAR

News

Circulars/Notifications News Latest

Delhi ITAT adjourns Roca & DIN cases sine-die given pendency of SC verdicts

Feb 24, 2026

News

Key Highlights of the US Supreme Court judgment striking down Trump Tariffs

Feb 20, 2026

News

Clinical Analysis of Draft Income Tax Rules, 2026 & Forms by Tax Compaas!

Feb 12, 2026

CBDT Corner

CBDT publishes draft Income tax Rules & Forms for New Income tax Act

Feb 07, 2026

Experts' Corner

Expert Columns

Prashant Maheshwari

Partner, Ernst & Young LLP

Finance Bill 2026 Signals a Turning Point for IT Captives and GCCs

Feb 04, 2026

Expert Columns

Mr Abhay Saboo

Partner, Transfer Pricing - SKP Co LLP

Budget 2026 – A Structural Reset of Safe Harbour Provisions and Fast Track APA for IT Services

Feb 02, 2026

Tax Ring

Finance Bill, 2025 - Transfer Pricing Proposal of 'Block Assessment' -...
Feb 01, 2025
Delhi HC's 'Wholesome Approach' on APA - Welcome Verdict?...
Jul 07, 2023

Updates

Income tax Appellate Tribunal Latest

ITAT: Deletes TP-adjustment qua interest on outstanding receivables in case of debt-free assessee

Mar 06, 2026

Income tax Appellate Tribunal

ITAT: Grants extension of stay of demand for 180 days or appeal’s disposal, whichever is earlier

Mar 06, 2026

Income tax Appellate Tribunal

ITAT: Grants assessee stay for recovery of outstanding demand

Mar 06, 2026

Income tax Appellate Tribunal

ITAT: Allows assessee’s stay application seeking stay of recovery of outstanding demand of Rs.26.96 crores…

Mar 05, 2026

Litigation Tracker

HC: Directs AO not to pass any assessment order on basis of TPO’s order

Jan 22, 2026

HC: Admits assessee’s appeal on jurisdiction issue u/s. 263

Jan 19, 2026

HC: Admits Revenue’s appeal on substantial questions of law involving jurisdictional issue

Dec 17, 2025

HC: Admits Mylan Laboratories’ appeal on amortization of goodwill, forex gain

Nov 28, 2025

Kaleidoscope

Reflections on Indian TP controversies: Corporate Guarantee

Jan 21, 2026

Reflections on Indian TP controversies – “Working Capital Adjustment”

Jul 09, 2024

BEPS

Stakeholders express concern over ‘twin-tests' in Draft Rules for Domestic Legislation on Scope under…
Apr 26, 2022
Stakeholders on Implementation Framework for Global Minimum Tax seek simplification, dispute resolution…
Apr 18, 2022

Taxsutra TV

Mr. Vijay Iyer bats for a more effective dispute resolution mechanism, easier compliances, effective tax rates

Jan 30, 2022

Rishabh Kumar Sawansukha, Vice President – Taxation, Snapdeal

Nov 19, 2015

Book Reviews

Tangible Guide to Intangibles

Transfer Pricing Demystified

Taxsutra Insights

Taxsutra Monthly TP Digest: Significant TP judgments for…

Feb 24, 2026

Reflections on Indian TP controversies – Reassessment u/s…

Dec 10, 2025

Loophole Games - A Treatise on Tax Avoidance Strategies (4th Edition, 2024)

First on Taxsutra

Search Judgment Aftermath - Revenue seeks SC's clarification vis-a-vis Sec.148 proceedings

First on Taxsutra

SC holds 'substantial question of law' lies before HC on comparable selection & ALP…

First on Taxsutra

SC decisively sets aside/reverses Karnataka HC judgment on comparables matter, allows Revenue appeal…

Experts' Corner

Expert Columns

Prashant Maheshwari

Partner, Ernst & Young LLP

Finance Bill 2026 Signals a Turning Point for IT Captives and GCCs

Feb 04, 2026

Expert Columns

Mr Abhay Saboo

Partner, Transfer Pricing - SKP Co LLP

Budget 2026 – A Structural Reset of Safe Harbour Provisions and Fast Track APA for IT Services

Feb 02, 2026

Global TP Battleground

Intra Group Debt Financing: UK Ruling on TP and Corporate Tax Considerations

Aug 27, 2024

Australian Federal Court ruling on Commercial Rationality - An Analysis

Apr 15, 2024

Loophole Games - A Treatise on Tax Avoidance Strategies (4th Edition, 2024)

Tax Ring

Finance Bill, 2025 - Transfer Pricing Proposal of 'Block Assessment' -...
Feb 01, 2025
Delhi HC's 'Wholesome Approach' on APA - Welcome Verdict?...
Jul 07, 2023

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Home
Direct Tax
Transfer Pricing
- All
- Rulings
  - Rulings
  - Updates
- Litigation Tracker
- News
  - All
  - News
  - APA Space
  - Around the World
  - CBDT Corner
- Experts' Corner
- Tax Ring
- Insights
- Kaleidoscope
- BEPS
- Media
  - Taxsutra TV
  - Podcast
- Book Reviews
GST
- All
- Rulings
- Litigation Tracker
- News
- Experts' Corner
- Tax Ring
- Insights
- GST Council Meetings
- Media
  - Gstsutra TV
  - Podcast
- Book Reviews
Indirect Tax
LawStreetIndia
Learning Hub
Databases
- Atoll
- Taxsutra Database
Reservoir
Greentick