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Transfer Pricing

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Aerial view of colorful high-rise buildings in Chennai, India, under a clear sky.
Posted inBlog

ITAT Chennai Directs Fresh Examination of Transfer Pricing Matters and Dismisses Revenue Appeal on Forex Loss

ITAT Chennai remands transfer pricing matters for fresh review while dismissing the Revenue appeal concerning foreign exchange losses, software depreciation, and secondment payments.
Posted by Prasenjit Bhowmik September 20, 2026
Scenic view of architectural buildings and greenery in Dhaka, Bangladesh.
Posted inBlog

ITAT Kolkata Rules in Favor of Taxpayer on Pass-Through AE Purchases

ITAT Kolkata deletes a significant transfer pricing adjustment after determining the associated enterprise acted strictly as a pass-through entity.
Posted by Prasenjit Bhowmik September 16, 2026
Closeup image of a law book titled 'The Law' on a wooden desk with scales of justice.
Posted inBlog

ITAT Mumbai Rules Section 92CA Reference Must Identify Specific Transaction

ITAT Mumbai rules that a Section 92CA reference must identify a transaction and the Transfer Pricing Officer cannot determine a Permanent Establishment.
Posted by Prasenjit Bhowmik September 16, 2026
A pen pointing to a financial graph showing sales and total costs.
Posted inBlog

Assured-Margin Model and Double Transfer Pricing Adjustments in Income Tax

Explore how the ITAT Mumbai addressed nil valuation of real services, preventing double transfer pricing adjustments in income tax proceedings.
Posted by Prasenjit Bhowmik September 7, 2026
Form 48: Accountant's Report for International & Specified Domestic Transactions
Posted inBlog

Form 48: Accountant’s Report for International & Specified Domestic Transactions

Learn how the new Form 48 streamlines transfer pricing disclosures and compliance for your international and specified domestic transactions.
Posted by Prasenjit Bhowmik August 22, 2026
CBDT Introduces Form 49 for Simplified Electronic Safe Harbour Applications Starting April 2026
Posted inBlog

CBDT Introduces Form 49 for Simplified Electronic Safe Harbour Applications Starting April 2026

The Central Board of Direct Taxes (CBDT) has announced the upcoming introduction of a unified tax document designated as Form 49, effective April 1, 2026. This new administrative instrument replaces…
Posted by Prasenjit Bhowmik August 14, 2026
CBDT Introduces Form 48 for International and Specified Domestic Transactions
Posted inBlog

CBDT Introduces Form 48 for International and Specified Domestic Transactions

Discover how the new CBDT Form 48 streamlines transfer pricing disclosures and compliance for international and domestic corporate transactions.
Posted by Prasenjit Bhowmik August 12, 2026
ITAT Mumbai Upholds 0.5% Corporate Guarantee Fee and Permits ESOP Deductions
Posted inBlog

ITAT Mumbai Upholds 0.5% Corporate Guarantee Fee and Permits ESOP Deductions

Discover how the ITAT Mumbai ruling on corporate guarantee fees and ESOP deductions impacts tax disputes and transfer pricing for businesses.
Posted by Prasenjit Bhowmik August 7, 2026
Global Overhead Charges Not Taxable as Fees for Included Services: Mumbai ITAT
Posted inBlog

Global Overhead Charges Not Taxable as Fees for Included Services: Mumbai ITAT

In a notable tax jurisprudence development, the Mumbai Bench of the Income Tax Appellate Tribunal (ITAT) has ruled that global overhead charges do not qualify as Fees for Included Services…
Posted by Prasenjit Bhowmik July 31, 2026

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