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Flash

CBDT releases detailed FAQs on ITA, 2025 related amendments in TOLA, 2026

Govt. to introduce Taxation & Other Laws (Amendment) Bill, 2026 to replace Ordinance & amend ITA, 2025

CBDT releases Annual APA Report for FY 2025-26

Mauritius ratifies 2024 DTAA protocol basis PM Modi's assurances, 'favourable' stand of Indian authorities

HC: Subsequent communication of DIN through intimation doesn't invalidate orders, constitutes compliance with Circular 19/2019

ASG N. Venkataraman re-appointed for new 3 year term

Bombay HC dismisses Revenue's appeal in GIA involving refund granted pursuant to APA

HC: Despite retro amendment to Sec. 144C, grants interim relief; Stays assessment order

CBDT amends Income-tax Rules to clarify grandfathering under GAAR Chapter

CBDT notifies ITR Forms for AY 2026-27

First on Taxsutra

Key Takeaways from Annual APA Report for FY 2025-26

First on Taxsutra

ITAT: Quashes draft assessment order as time-barred; Sec. 153(5A) limitation applies to Sec. 263…

First on Taxsutra

HC: Dismisses Revenue’s appeal challenging deletion of addition u/s. 10A(7) made for assessee’…

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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: Directs fresh verification of TP-adjustments qua US tax return preparation, secondment and software…

Aug 28, 2026

Income tax Appellate Tribunal

ITAT: Allows capacity utilization adjustment given Covid-19 pandemic impact, deletes TP-addition for captive…

Aug 27, 2026

Income tax Appellate Tribunal

ITAT: Deletes TP-adjustments qua exclusivity / transition-fee payments made to British Telecom by Tech…

Aug 24, 2026

High Court

HC: Quashes ITAT-order on limitation considering Sec.92CA retro amendment, remits matter for decision on…

Aug 22, 2026

Trending Topics :

Refund
Tiger Global Case
Union Budget 2026
Income Tax Bill, 2025
Trump Tariffs

News

CBDT Corner Latest

CBDT releases detailed FAQs on ITA, 2025 related amendments in TOLA, 2026

Aug 04, 2026

News

Govt. to introduce Taxation & Other Laws (Amendment) Bill, 2026 to replace Ordinance & amend ITA,…

Aug 03, 2026

News T-Street Buzz

M&A veteran Amrish Shah to join Adani Group as Tax Head

Jul 31, 2026

News

Key Takeaways from Annual APA Report for FY 2025-26

Jul 27, 2026

Experts' Corner

Expert Columns

Munjal Almoula

Managing Partner, Tax & Regulatory Advisory, BDO India

Transfer Pricing Is Moving from Compliance to Control

Aug 26, 2026

Expert Columns

Amit Dattani

Head of Transfer Pricing, CLA Emirates

UAE Transfer Pricing: the Second Filing Cycle Asks Harder Questions

Aug 21, 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: Allows assessee's MA, rectifies apparent errors; States other observations of earlier order…

Aug 31, 2026

High Court

HC: Sets aside TPO's order passed without issuing SCN u/s.92C(3); Notice u/s.92CA(2) seeking…

Aug 31, 2026

Income tax Appellate Tribunal

ITAT: Disapproves Revenue's manner of filing appeal, affirms CIT(A)'s remand w.r.t ALP of selling…

Aug 31, 2026

Income tax Appellate Tribunal

ITAT: Restricts corporate guarantee to 0.5% instead of 4%; Follows earlier order

Aug 31, 2026

Litigation Tracker

SC: Issues notice in Revenue’s SLP in Sun Pharma on validity of final assessment orders

Aug 18, 2026

HC: Admits Revenue’s appeal on issues w.r.t interest on loans and Letter of Comfort

Aug 17, 2026

HC: Admits Revenue’s appeal w.r.t entity-level benchmarking combining domestic & international…

Aug 06, 2026

SC: Grants leave in Revenue's SLP on AMP expenses in case of Wrigley India

Jul 22, 2026

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

Transfer Pricing Navigating Arm's Length with ITA, 2025

Available on Reservoir

Tangible Guide to Intangibles

Taxsutra Insights

Reflections on Indian TP controversies- Inter-company balance…

May 28, 2026

Reflections on Indian TP controversies: Specified Domestic Transaction…

Apr 28, 2026

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

First on Taxsutra

Key Takeaways from Annual APA Report for FY 2025-26

First on Taxsutra

ITAT: Quashes draft assessment order as time-barred; Sec. 153(5A) limitation applies to Sec. 263…

First on Taxsutra

HC: Dismisses Revenue’s appeal challenging deletion of addition u/s. 10A(7) made for assessee’…

Experts' Corner

Expert Columns

Munjal Almoula

Managing Partner, Tax & Regulatory Advisory, BDO India

Transfer Pricing Is Moving from Compliance to Control

Aug 26, 2026

Expert Columns

Amit Dattani

Head of Transfer Pricing, CLA Emirates

UAE Transfer Pricing: the Second Filing Cycle Asks Harder Questions

Aug 21, 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