Transfer Pricing
![Interest on Foreign Currency Loan to AE at Rate Higher Than Internal CUP is at Arm’s Length: ITAT [Read Order]](https://images.taxscan.in/h-upload/2026/03/02/2127543-nterest-on-foreign-currency-loan-to-aejpg.webp "Interest on Foreign Currency Loan to AE at Rate Higher Than Internal CUP is at Arm’s Length: ITAT [Read Order]")
Interest on Foreign Currency Loan to AE at Rate Higher Than Internal CUP is at Arm’s Length: ITAT [Read Order]
The Income Tax Appellate Tribunal (ITAT), NewDelhi, held that interest on foreign currency loan to Associated Enterprises(AE) at a rate higher than...
![TPO Must Supply Copies of Relied-Upon Agreements Before Passing Transfer Pricing Order: Delhi HC Sets Aside Royalty Adjustment [Read Order]](https://images.taxscan.in/h-upload/2026/02/17/2126127-tpo-transfer-pricing-delhi-hc-royalty-adjustment-taxscan.webp "TPO Must Supply Copies of Relied-Upon Agreements Before Passing Transfer Pricing Order: Delhi HC Sets Aside Royalty Adjustment [Read Order]")
![Entire Income Tax Assessment Must Conclude within 30 Months where TPO Reference Exists: ITAT [Read Order]](https://images.taxscan.in/h-upload/2026/02/04/2123752-entire-income-tax-assessment-must-conclude-within-30-months-taxscan.webp "Entire Income Tax Assessment Must Conclude within 30 Months where TPO Reference Exists: ITAT [Read Order]")
![Manufacturing Entity Fails to Qualify 75% Trading Turnover Filter: ITAT Orders Deletion of Comparable [Read Order]](https://images.taxscan.in/h-upload/2026/01/11/2118331-manufacturing-entity-trading-turnover-itat-orders-taxscan.webp "Manufacturing Entity Fails to Qualify 75% Trading Turnover Filter: ITAT Orders Deletion of Comparable [Read Order]")
![Relief to Thermo Fisher in Transfer Pricing Dispute: ITAT Partly Allows Appeal on Royalty ALP, Benchmarking, Comparables, Aggregation and Working Capital Adjustments [Read Order]](https://images.taxscan.in/h-upload/2026/01/11/2118312-thermo-fisher-transfer-pricing-itat-appeal-royalty-alp-benchmarking-comparables-aggregation-working-capital-adjustments-taxscan.webp "Relief to Thermo Fisher in Transfer Pricing Dispute: ITAT Partly Allows Appeal on Royalty ALP, Benchmarking, Comparables, Aggregation and Working Capital Adjustments [Read Order]")
Transfer Pricing Dispute: Delhi HC Refuses to Condone Income Tax Department’s 1285-Day Delay in Re-Filing Appeal [Read Order]
The Delhi High Court has rejected the Income Tax Department's request to condone a huge delay of 1285 days in re-filing their appeal in a transfer pricing case. The court said the department gave...
![Transfer Pricing Dispute: Delhi HC Refuses to Condone Income Tax Department’s 1285-Day Delay in Re-Filing Appeal [Read Order]](https://images.taxscan.in/h-upload/2025/12/30/2115842-delhi-high-court-condone-income-tax-department-condonation-of-delay-condonation-condonation-delay-taxscan.webp "Transfer Pricing Dispute: Delhi HC Refuses to Condone Income Tax Department’s 1285-Day Delay in Re-Filing Appeal [Read Order]")
S.56(2)(viib) Not Applicable to Shares issued to Non-Resident Holding Company: ITAT Deletes ₹198 Cr Addition [Read Order]
The Bangalore Bench of the Income Tax Appellate Tribunal (ITAT) deleted a massive addition of ₹198 crores made under Section 56(2)(viib) and held that the provisions aimed at taxing share premiums ...
![S.56(2)(viib) Not Applicable to Shares issued to Non-Resident Holding Company: ITAT Deletes ₹198 Cr Addition [Read Order]](https://images.taxscan.in/h-upload/2025/12/20/2113435-itat-deletes-198-cr-addition-taxscan.webp "S.56(2)(viib) Not Applicable to Shares issued to Non-Resident Holding Company: ITAT Deletes ₹198 Cr Addition [Read Order]")
Commercial Expediency Cannot be Rewritten by TPO: Delhi HC upholds Avery Dennison’s Intra-Group Services at Arm’s Length
The Delhi High Court has dismissed an appeal filed under Section 260A of the IncomeTax Act, 1961, holding that no substantial question of law arose from the findings accepting the arm’s length...
TPO's Failure to Adopt Prescribed Benchmarking Method u/s 92C: ITAT Deletes Protective TP Addition on Interest Income [Read Order]
The Pune Bench of the Income Tax Appellate Tribunal (ITAT) deleted a protective Transfer Pricing (TP) adjustment of ₹13,81,700 on interest income and ruled that the Transfer Pricing Officer (TPO) ...
![TPOs Failure to Adopt Prescribed Benchmarking Method u/s 92C: ITAT Deletes Protective TP Addition on Interest Income [Read Order]](https://images.taxscan.in/h-upload/2025/11/29/2108703-itat-pune-tpo-taxscan.webp "TPOs Failure to Adopt Prescribed Benchmarking Method u/s 92C: ITAT Deletes Protective TP Addition on Interest Income [Read Order]")
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 for transfer pricing differences under Section ...
![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/2025/11/07/2103145-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]")
