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Flash

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

Finance Bill, 2026 receives President's assent

In seminal case involving APA - Transfer Pricing interplay, ASG Venkataraman fires opening salvo

Copy of Explanatory Memorandum justifying Finance Bill Amendments

Lok Sabha passes Finance Bill, 2026 with amendments

Copy of Amendments to Finance Bill, 2026 moved by Govt. in Parliament

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: Deletes TP-adjustment w.r.t contract manufacturing / R&D made solely basis margins agreed under…

Jul 10, 2026

Income tax Appellate Tribunal

ITAT: Notes Coca Cola India-branch's debt-free status, rejects TPO's working capital adjustment…

Jul 09, 2026

Income tax Appellate Tribunal

ITAT: Upholds deletion of adjustments qua export sales, guarantee commission, service charges, SDTs for IPCA…

Jun 25, 2026

Income tax Appellate Tribunal

ITAT: Assessee only reseller/distributor of sim-cards etc, embossing logo will not alter functional profile…

Jun 19, 2026

Trending Topics :

Tiger Global Case
Union Budget 2026
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News

News Latest

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

Jun 21, 2026

Around the World

UK HMRC launches technical consultation on ICTS, a new mandatory reporting framework for multinationals

Jun 19, 2026

News

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

Jun 16, 2026

Around the World

Singapore publishes e-tax guide, provides 9th Edition of comprehensive TP guidelines

Jun 09, 2026

Experts' Corner

Expert Columns

Nithya Srinivasan

Founder, VSTN

Understanding Pillar Two: Implementation and Implications – Impact on Indian HQ Groups

Jun 30, 2026

Expert Columns

Ravi Gupta

Head of Transfer pricing at TPXcelerator.Ai

Tech Transformation of Transfer Pricing: Low-Hanging Fruits & Beyond

Jun 15, 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 notional interest on outstanding receivables, considers assessee's debt…

Jul 10, 2026

Income tax Appellate Tribunal

ITAT: Rectifies Tribunal’s order; Excludes companies having high turnover

Jul 10, 2026

High Court

HC: Disposes of writ petitions on issue of refund release

Jul 10, 2026

Income tax Appellate Tribunal

ITAT: Deletes SDT-adjustment w.r.t transfer of wind energy, follows Prabhu Spinning Mills ruling

Jul 09, 2026

Litigation Tracker

HC hears petition challenging retro amendment w.r.t limitation, calls on Tribunal to defer final order

Jul 10, 2026

HC: Admits Revenue’s appeal challenging adjustment made and benchmarking method

Jul 01, 2026

HC: Allows AO to pass a draft assessment order, directs no effect be given to it until further orders

Jun 03, 2026

HC: Admits Revenue’s appeal on 80IA claim, applicability of ‘market value’ vs ALP

May 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

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

Nithya Srinivasan

Founder, VSTN

Understanding Pillar Two: Implementation and Implications – Impact on Indian HQ Groups

Jun 30, 2026

Expert Columns

Ravi Gupta

Head of Transfer pricing at TPXcelerator.Ai

Tech Transformation of Transfer Pricing: Low-Hanging Fruits & Beyond

Jun 15, 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