Judgement

The ITAT Ahmedabad follows Gujarat High Court Ruling and holds Nil ALP Determination unsustainable without proper benchmarking.

ITAT Deletes Rs. 20.17 Crore Transfer Pricing Adjustment on Intra-Group Services 

News

Pfizer India faces a Rs 1.26 crore penalty under Section 271G over alleged non-submission of detailed information during a FY23 transfer pricing audit.

Pfizer India Receives Rs 1.26 Crore Penalty Order From Income Tax Department Over Transfer Pricing Audit for FY23

ICAI has released a practical handbook covering year-end transfer pricing compliance, including Form 3CEB, documentation, master file, country-by-country reporting and a unified compliance calendar.

ICAI Releases Transfer Pricing Compliance Handbook with Year-End Checklist for FY 2025-26

ITAT deleted the Rs 1.13 crore transfer pricing adjustment after finding that depreciation was treated inconsistently while comparing the assessee’s operating margin with comparable companies.

ITAT Deletes Rs 1.13 Crore Transfer Pricing Adjustment, Flags Inconsistent Depreciation Treatment

ITAT deletes the TP adjustment on Rs 94.33 crore CCD interest, holding that CCDs retain their debt character until conversion and that the 12.37% effective rate was within the comparable range.

ITAT Deletes Transfer Pricing Adjustment on 14% CCD Interest Paid to Foreign AE, Rejects Equity Recharacterisation of CCDs

ITAT remands Honda R&D’s Rs 50.19 lakh transfer pricing adjustment for fresh consideration, citing favourable findings in the subsequent AY 2021-22 proceedings.

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ITAT Deletes Rs. 20.17 Crore Transfer Pricing Adjustment on Intra-Group Services

Pfizer India Receives Rs 1.26 Crore Penalty Order From Income Tax Department Over Transfer Pricing Audit for FY23

ICAI Releases Transfer Pricing Compliance Handbook with Year-End Checklist for FY 2025-26

ITAT Deletes Rs 1.13 Crore Transfer Pricing Adjustment, Flags Inconsistent Depreciation Treatment

ITAT Deletes Transfer Pricing Adjustment on 14% CCD Interest Paid to Foreign AE, Rejects Equity Recharacterisation of CCDs

ITAT Remands Rs 50.19 Lakh Transfer Pricing Adjustment to AO/TPO for Fresh Consideration, Citing Subsequent Year’s Favourable Findings