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Flash

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

Lok Sabha passes Income-tax Bill, 2025

In New IT Bill latest version, adverse AMT taxation proposal done away with

New IT Bill latest version maintains status quo on loss carry forward provision

In new Income tax Bill latest version, important amendment vis-a-vis AE shareholding threshold

Snapshot of key proposals in Taxation Laws Amendment Bill, 2025, for amending IT Act, 1961

Copy of Income-tax Bill as reintroduced in Parliament

SC: 50 Key Excerpts from SC's split verdict in Shelf Drilling controversy

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…

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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
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

High Court Latest

HC: Upholds ITAT’s decision confirming Sec.10AA deduction on assessee’s voluntary TP-adjustment pursuant to…

Nov 19, 2025

Income tax Appellate Tribunal

ITAT: Third member holds rate of electricity purchased from SEB represents appropriate CUP for Sec.80IA…

Nov 19, 2025

High Court

HC: Upholds ITAT's deletion of TP-adjustment w.r.t payment for advisory services absent any perversity…

Nov 13, 2025

High Court

HC: Holds TP-addition non-est, as proceedings to give effect to DRP’s directions barred by limitation

Oct 30, 2025

Trending Topics :

MFN Clause
Reassessment
Search Assessments
Union Budget - 2025
Charitable Trusts

News

News Latest

Govt notifies tolerance range for AY 2025-26; Retains 1% for wholesale traders & 3% for others

Nov 07, 2025

News

10 Unforgettable Zingers/ Sharp One-liners from ITAT's Netflix ruling

Oct 29, 2025

News

CBDT releases 7th APA Annual Report for FY 2024-25, highlights first MAPA signing

Oct 17, 2025

News

'Tax Beats' - Podcast to Demystify Income-tax Act, 2025!

Oct 06, 2025

Experts' Corner

Expert Columns

Sandeep Pincha

Chartered Accountant

DRP vs CIT(A): Strategic Choices and Procedural Complexities in Tax Dispute Resolution

Nov 19, 2025

Expert Columns

Nandini Bhatia

Bhatia & Bhatia, Chartered Accountants

Navigating Tax and Transfer Pricing for Global Capability Centres (GCCs) in India: Key Considerations for MNCs

Sep 09, 2025

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: Remits TP-adjustment qua electricity-sale; Directs AO/TPO to adopt gross SEB rate instead of base rate…

Nov 19, 2025

Income tax Appellate Tribunal

ITAT: Remits TP-adjustment w.r.t project execution services, directs DRP to consider assessee's…

Nov 19, 2025

Income tax Appellate Tribunal

ITAT: Excludes functionally dissimilar comparables with huge turnover; Applies LIBOR + 200 bps for…

Nov 18, 2025

Income tax Appellate Tribunal

ITAT: Directs TPO/AO to consider TP documentation & segmental details afresh for computing ALP

Nov 18, 2025

Litigation Tracker

HC: Admits Revenue’s appeal on comparables selection in case of Optiva Technologies

Nov 14, 2025

HC: Admits Revenue’s appeal on adjustments qua corporate guarantee and outstanding receivables

Nov 06, 2025

HC: Frames question related to validity of final assessment order in case of Honda R&D

Oct 23, 2025

HC: Admits Revenue’s appeal against ITAT-order deleting AMP adjustment in case of Kellogg India

Sep 29, 2025

Kaleidoscope

Reflections on Indian TP controversies – “Working Capital Adjustment”

Jul 09, 2024

Reflections on Indian TP controversies – "Profit Split Method”

Aug 04, 2023

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

Reflections on Indian TP controversies – Marketing intangible/ AMP…

Nov 10, 2025

Other Method – A Review In Light of Select Rulings

Aug 22, 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

Sandeep Pincha

Chartered Accountant

DRP vs CIT(A): Strategic Choices and Procedural Complexities in Tax Dispute Resolution

Nov 19, 2025

Expert Columns

Nandini Bhatia

Bhatia & Bhatia, Chartered Accountants

Navigating Tax and Transfer Pricing for Global Capability Centres (GCCs) in India: Key Considerations for MNCs

Sep 09, 2025

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