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Flash

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

CBDT includes revised Critical Assumption in APAs in respect of updated Safe Harbour Rules

Copy of English version of Income tax Rules, 2026 as notified by Govt.

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

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: AO not required to pass draft order if matter restored to DRP by higher forum

Apr 17, 2026

Income tax Appellate Tribunal

ITAT: Deletes TP-adjustment w.r.t interest on ECB for Vodafone Idea, considers RBI-approved ceiling

Apr 09, 2026

High Court

HC: Affirms restriction of royalty on export sales @ 1%; Assessee cannot adopt inconsistent positions across…

Apr 06, 2026

Income tax Appellate Tribunal

ITAT: Deletes adjustment made on Restricted Stock Units allotted to employees of Whatsapp Application…

Mar 31, 2026

Trending Topics :

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

News

News Latest

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

Apr 01, 2026

CBDT Corner News

CBDT records highest ever signed APAs in 2025-26 including 84 BAPAs

Mar 31, 2026

CBDT Corner

CBDT notifies ITR Forms for AY 2026-27

Mar 31, 2026

News

Finance Bill, 2026 receives President's assent

Mar 31, 2026

Experts' Corner

Expert Columns

Ashwin Vishwanathan

Partner, EY LLP

Geopolitics Shaping Transfer Pricing & Suggested Actions

Mar 10, 2026

Expert Columns

Prashant Maheshwari

Partner, Ernst & Young LLP

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

Feb 04, 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: Upholds restriction of TP-adjustment to AE-transactions, grant of capacity utilization/working capital…

Apr 17, 2026

Income tax Appellate Tribunal

ITAT: Quashes final assessment order passed u/s 144C(13) without following DRP’s direction

Apr 16, 2026

Income tax Appellate Tribunal

ITAT: Rules on comparables qua distribution segment, deletes adjustment qua outstanding receivables

Apr 15, 2026

Income tax Appellate Tribunal

ITAT: Holds forex gain as operating income, no separate adjustment required for outstanding receivables

Apr 15, 2026

Litigation Tracker

Admits appeal against ITAT-order pertaining to AMP expenses

Apr 17, 2026

Writ petition now assails Shelf Drilling related retrospective amendments

Apr 17, 2026

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

Mar 30, 2026

HC: Stays operation of 92CA(1) reference along with assessment proceedings

Mar 30, 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

Tangible Guide to Intangibles

Transfer Pricing Demystified

Taxsutra Insights

Reflections on Indian TP controversies – Revision u/s 263 w.r.t…

Mar 23, 2026

Taxsutra Monthly TP Digest: Significant TP judgments for…

Feb 24, 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

Ashwin Vishwanathan

Partner, EY LLP

Geopolitics Shaping Transfer Pricing & Suggested Actions

Mar 10, 2026

Expert Columns

Prashant Maheshwari

Partner, Ernst & Young LLP

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

Feb 04, 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