Transfer Pricing
![FinMin Notifies 1% and 3% Tolerance Range for Transfer Pricing Adjustments u/s 92C(2) of Income Tax [Read Notification]](https://images.taxscan.in/h-upload/2025/11/07/500x300_2103145-finmin-tolerance-range-transfer-pricing-adjustments-income-tax-taxscan.webp "FinMin Notifies 1% and 3% Tolerance Range for Transfer Pricing Adjustments u/s 92C(2) of Income Tax [Read Notification]")
FinMin Notifies 1% and 3% Tolerance Range for Transfer Pricing Adjustments u/s 92C(2) of Income Tax [Read Notification]
The Ministry of Finance (Department of Revenue) has issued Notification No. 157/2025 [S.O. 5053(E)] dated November 6, 2025, announcing new limits...
![Eligibility for S.10AA Deduction on Voluntary TP Adjustments Under APA: ITAT Upholds CIT(A)s Decision [Read Order]](https://www.taxscan.in/wp-content/uploads/2025/02/Voluntary-TP-Adjustments-ITAT-ITAT-Upholds-CIT-Advance-Pricing-Agreement-voluntary-Transfer-Pricing-section-10AA-of-Income-Tax-Act-EYGBS-Assessment-Year-Assessment-Taxscan.jpg "Eligibility for S.10AA Deduction on Voluntary TP Adjustments Under APA: ITAT Upholds CIT(A)s Decision [Read Order]")
Assessee’s Foreign AE not used as Tested Party in Previous Years: Delhi HC dismisses Challenge to Transfer Pricing Addition [Read Order]
In a recent the Delhi High Court dismissed the challenge to the transfer pricing addition, citing that the assessee’s foreign associated enterprise had not been used as the tested party in previous...
ITAT directs to Eliminate Eclerx from final list of comparables chosen for Benchmarking KPO Transactions of Crisil [Read Order]
The Income Tax Appellate Tribunal ( ITAT ), Mumbai bench directed to eliminate Eclerx from the final list of comparable chosen for benchmarking Knowledge process outsourcing ( KPO ) services. The...
![ITAT directs to Eliminate Eclerx from final list of comparables chosen for Benchmarking KPO Transactions of Crisil [Read Order]](https://www.taxscan.in/wp-content/uploads/2024/03/ITAT-ITAT-Mumbai-Income-Tax-Eclerx-Knowledge-process-outsourcing-KPO-benchmarking-taxscan.jpg "ITAT directs to Eliminate Eclerx from final list of comparables chosen for Benchmarking KPO Transactions of Crisil [Read Order]")
No Exclusion of comparable if Data available on Records can be reasonably Extrapolated: ITAT [Read Order]
In a recent ruling the Mumbai bench of the Income Tax Appellate Tribunal ( ITAT ) observed that no exclusion of comparable if data available on records can be Reasonably Extrapolated This appeal...
![No Exclusion of comparable if Data available on Records can be reasonably Extrapolated: ITAT [Read Order]](https://www.taxscan.in/wp-content/uploads/2024/03/No-Exclusion-comparable-Data-Records-Extrapolated-ITAT-taxscan.jpg "No Exclusion of comparable if Data available on Records can be reasonably Extrapolated: ITAT [Read Order]")
Rejecting TP Analysis without Giving any Specific Reason is invalid, CIT(A) validates TP Report: ITAT upholds Order of CIT(A) [Read Order]
The Mumbai bench of the Income Tax Appellate Tribunal ( ITAT ) upheld the order of the Commissioner of Income Tax (Appeals) which validated the Transfer Pricing ( TP ) report by holding that...
![Rejecting TP Analysis without Giving any Specific Reason is invalid, CIT(A) validates TP Report: ITAT upholds Order of CIT(A) [Read Order]](https://www.taxscan.in/wp-content/uploads/2024/01/T-P-Analysis-CITA-TP-Report-ITAT-ITAT-Upholds-Order-of-CITA-Rejecting-T-P-Analysis-without-Giving-any-Specific-Reason-taxscan.jpg "Rejecting TP Analysis without Giving any Specific Reason is invalid, CIT(A) validates TP Report: ITAT upholds Order of CIT(A) [Read Order]")
Qualifying Activities under TTS is outside provisions of TP: ITAT deletes addition on account of allocation of Head Office Expenses [Read Order]
The Income Tax Appellate Tribunal (ITAT) Mumbai bench while deleting additions made towards the allocation of head office expenses held that qualifying activities under Tonnage Tax Scheme (TTS) are...
![Qualifying Activities under TTS is outside provisions of TP: ITAT deletes addition on account of allocation of Head Office Expenses [Read Order]](https://www.taxscan.in/wp-content/uploads/2023/10/Qualifying-Activities-TTS-outside-provisions-TP-ITAT-addition-allocation-Head-Office-Expenses-taxscan.jpg "Qualifying Activities under TTS is outside provisions of TP: ITAT deletes addition on account of allocation of Head Office Expenses [Read Order]")
ITAT deletes TP Adjustment by TPO towards Payment of Royalty on Technology paid to Cadbury Adams USA LLC, and Cadbury Enterprises Pte Ltd [Read Order]
The Mumbai Bench of Income Tax Appellate Tribunal (ITAT) has deleted the Transfer Pricing (TP) adjustment by the Transfer Pricing Officer (TPO) towards the payment of royalty on technology paid to...
![ITAT deletes TP Adjustment by TPO towards Payment of Royalty on Technology paid to Cadbury Adams USA LLC, and Cadbury Enterprises Pte Ltd [Read Order]](https://www.taxscan.in/wp-content/uploads/2023/09/ITAT-TP-Adjustment-by-TPO-towards-Payment-Royalty-on-Technology-paid-to-Cadbury-Adams-USA-LLC-Cadbury-Enterprises-Pte-Ltd.jpg "ITAT deletes TP Adjustment by TPO towards Payment of Royalty on Technology paid to Cadbury Adams USA LLC, and Cadbury Enterprises Pte Ltd [Read Order]")