Transfer Pricing

Blog, News, Transfer Pricing

May 26, 2025

[Opinion] Revisiting Historical Transfer Pricing – Lessons from a $9 Billion IRS Dispute

Amer Qureshi & Poojan Choudhary … Continue reading “[Opinion] Revisiting Historical Transfer Pricing – Lessons from a $9 Billion IRS Dispute”

Blog, News, Transfer Pricing

May 2, 2025

No AMP Adjustment When APA Margin is Followed | ITAT

Case Details: AstraZeneca Pharma India … Continue reading “No AMP Adjustment When APA Margin is Followed | ITAT”

News, Blog, Transfer Pricing

April 1, 2025

[Opinion] Expanding Safe Harbour Rules to Restrain Transfer Pricing Disputes

Rajiv Bhutani – [2025] 172 … Continue reading “[Opinion] Expanding Safe Harbour Rules to Restrain Transfer Pricing Disputes”

Blog, News, Transfer Pricing

February 19, 2025

Sec. 271AA Penalty Could Not Be Levied if AO Failed to Provide Details Regarding Docs. Not Submitted Before TPO | ITAT

Case Details: DCIT v. Priya … Continue reading “Sec. 271AA Penalty Could Not Be Levied if AO Failed to Provide Details Regarding Docs. Not Submitted Before TPO | ITAT”

Blog, News, Transfer Pricing

February 7, 2025

Sec. 92BA Applies to All Assessees Regardless of Section 80-IA Deduction Is Claimed | ITAT

Case Details: Sanghi Industries Ltd. … Continue reading “Sec. 92BA Applies to All Assessees Regardless of Section 80-IA Deduction Is Claimed | ITAT”

Blog, News, Transfer Pricing

January 22, 2025

No Revision Just Because AO Didn’t Conduct Any Minimum Enquiry Before Allowing a Claim | ITAT

Case Details: Beam Global Spirits … Continue reading “No Revision Just Because AO Didn’t Conduct Any Minimum Enquiry Before Allowing a Claim | ITAT”

Blog, News, Transfer Pricing

January 17, 2025

[Opinion] Don’t Let Margins Miss the Arm’s Length Mark | True-Up Your Transfer Pricing in UAE

Mohit Gupta – [2025] 170 … Continue reading “[Opinion] Don’t Let Margins Miss the Arm’s Length Mark | True-Up Your Transfer Pricing in UAE”

Blog, News, Transfer Pricing

December 28, 2024

[Opinion] Limitation on Interest Deduction in Certain Cases (Section 94B)

CA Rohan Sogani & Samarth … Continue reading “[Opinion] Limitation on Interest Deduction in Certain Cases (Section 94B)”

Blog, News, Transfer Pricing

December 11, 2024

[Opinion] Transfer Pricing Nuances of Intra Group Services in the Financial Services Industry

Shefali Shah & Darshak Pandya … Continue reading “[Opinion] Transfer Pricing Nuances of Intra Group Services in the Financial Services Industry”

News, Blog, Transfer Pricing

November 25, 2024

[Opinion] Insurance and Reinsurance Sector – Transfer Pricing Interplay

Parag Gor – [2024] 168 … Continue reading “[Opinion] Insurance and Reinsurance Sector – Transfer Pricing Interplay”