Dissimilar comparables in Transfer Pricing Owing to Intangibles as Goodwill and Product Development Costs: Delhi HC upholds Exclusion [Read Order]
In a recent ruling, the Delhi High Court upheld the exclusion of dissimilar comparables in transfer pricing due to intangibles such as goodwill and...
![ITAT deletes Notional Interest in Absence of Proof to Treat Share Application Money in Hands of Overseas AE as Loan [Read Order]](https://www.taxscan.in/wp-content/uploads/2024/10/ITAT-Income-Tax-Income-Tax-Appellate-Tribunal-ITAT-Mumbai-TAXSCAN.jpg "ITAT deletes Notional Interest in Absence of Proof to Treat Share Application Money in Hands of Overseas AE as Loan [Read Order]")
![ITAT directs Reassessment of JCB Indias ₹166.09 Crore TP Adjustment for Royalty Payments to Non-UK Entities in AY 2017-18 [Read Order]](https://www.taxscan.in/wp-content/uploads/2024/10/ITAT-ITAT-Delhi-Reassessment-of-JCB-Royalty-Payments-to-Non-UK-Entities-ITAT-directs-reassessment-Royalty-payments-TP-dispute-Taxscan.jpg "ITAT directs Reassessment of JCB Indias ₹166.09 Crore TP Adjustment for Royalty Payments to Non-UK Entities in AY 2017-18 [Read Order]")
![Relief to Ericsson: Supreme Court upholds deletion of ₹64.43 Cr Penalty u/s 271G of Income Tax Act [Read Judgement]](https://www.taxscan.in/wp-content/uploads/2024/09/Supreme-Court-Ericsson-Income-Tax-Income-Tax-Act-Ericsson-India-penalty-Section-271G-Income-Tax-Act-Ericsson-India-tax-penalty-case-taxscan.jpg "Relief to Ericsson: Supreme Court upholds deletion of ₹64.43 Cr Penalty u/s 271G of Income Tax Act [Read Judgement]")
![TP Adjustment cannot be at ‘NIL’ as determined by the TPO: ITAT directs TPO to consider ALP afresh [Read Order]](https://www.taxscan.in/wp-content/uploads/2024/09/Income-Tax-ITAT-TP-Adjustment-by-TPO-Intra-Group-Services-TAXSCAN.jpg "TP Adjustment cannot be at ‘NIL’ as determined by the TPO: ITAT directs TPO to consider ALP afresh [Read Order]")
No Notional Interest to be assumed by TPO on Deferred Receivables to Debt-Free Company: Delhi HC [Read Order]
The ruled that no notional interest can be assumed by the Transfer Pricing Officer ( TPO ) on deferred receivables from a debt-free company. The primary issue addressed was whether deferred...
![No Notional Interest to be assumed by TPO on Deferred Receivables to Debt-Free Company: Delhi HC [Read Order]](https://www.taxscan.in/wp-content/uploads/2024/09/Delhi-High-Court-Debt-Free-TPO-No-Notional-Interest-Taxscan.jpg "No Notional Interest to be assumed by TPO on Deferred Receivables to Debt-Free Company: Delhi HC [Read Order]")
Relief to Microsoft and Others as Delhi HC quashes Income Tax Assessment Order issued w/o Draft Order [Read Order]
In this case, one of the writ petitioners, Microsoft India, had filed its Income Tax Returns ( ITR ) on 30, 2008, for the Assessment Year 2008-2009. The returns filed were selected for scrutiny, and...
![Relief to Microsoft and Others as Delhi HC quashes Income Tax Assessment Order issued w/o Draft Order [Read Order]](https://www.taxscan.in/wp-content/uploads/2024/09/Income-Tax-Income-Tax-Returns-ITR-Microsoft-income-tax-case-India-TAXSCAN.jpg "Relief to Microsoft and Others as Delhi HC quashes Income Tax Assessment Order issued w/o Draft Order [Read Order]")
Punjab & Haryana HC deletes Arm's Length Price in absence of Justification in Comparables used During ALP Determination [Read Order]
The Punjab & Haryana High Court in a recent case deleted the Arm’s Length Price ( ALP ) in absence of justification in comparables used during ALP determination. It was held that Revenue...
India-Italy DTAA Not Applicable When Domestic Company Pays DDT u/s 115O of Income Tax Act: ITAT [Read Order]
The Pune bench of the Income Tax Appellate Tribunal (ITAT) ruled that the India-Italy Double Taxation Avoidance Agreement (DTAA) is not applicable when a domestic company pays Dividend Distribution...
![India-Italy DTAA Not Applicable When Domestic Company Pays DDT u/s 115O of Income Tax Act: ITAT [Read Order]](https://www.taxscan.in/wp-content/uploads/2024/08/TAA-Income-Tax-Act-DDT-ITAT-Dividend-Distribution-Tax-Section-115O-of-the-Income-Tax-Act-Income-Tax-Appellate-Tribunal-Taxscan.webp "India-Italy DTAA Not Applicable When Domestic Company Pays DDT u/s 115O of Income Tax Act: ITAT [Read Order]")
ITAT directs TPO to exclude Companies with Turnover exceeding or below 10 times for Transfer Pricing Comparable Analysis [Read Order]
The Hyderabad Bench of the Income Tax Appellate Tribunal orders the Transfer pricing officer ( TPO ) to apply the turnover filter to exclude companies with a Turnover of more than 10 times or less...
![ITAT directs TPO to exclude Companies with Turnover exceeding or below 10 times for Transfer Pricing Comparable Analysis [Read Order]](https://www.taxscan.in/wp-content/uploads/2024/08/Determination-of-ALP-Professional-Fee-AO-TPO-ITAT-Addition-transfer-pricing-adjustment-taxscan.jpg "ITAT directs TPO to exclude Companies with Turnover exceeding or below 10 times for Transfer Pricing Comparable Analysis [Read Order]")
ITAT allows weighted Income Tax Deduction u/s 32(2AB) wrt expenses incurred on clinical trials [Read Order]
The Hyderabad bench of the Income Tax Appellate Tribunal ( ITAT )Â allowed the weighted deduction in respect of the expenses incurred on clinical trials and held that the assessee is entitled to...
![ITAT allows weighted Income Tax Deduction u/s 32(2AB) wrt expenses incurred on clinical trials [Read Order]](https://www.taxscan.in/wp-content/uploads/2024/07/income-tax-deduction-clinical-trials-ITAT-Hyderabad-Income-Tax-Act-weighted-income-tax-deduction-tax-news-income-tax-income-tax-news-ITAT-taxscan-1.jpg "ITAT allows weighted Income Tax Deduction u/s 32(2AB) wrt expenses incurred on clinical trials [Read Order]")
Not Permissible for TPO to Engage in Restructuring of Transaction: Delhi HC dismisses Appeal [Read Order]
The Delhi High Court has held that it is not permissible for the Transfer Pricing Officer ( TPO ) to engage in the restructuring of a transaction. The bench of Justice Yashwant Varma and Justice...
