Tag Archives: Int Tax

Transfer pricing adjustment remanded for fresh evidence verification, while MAT addition on unexpired risks reserve is deleted.

By | August 27, 2026
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Transfer pricing adjustment remanded for fresh evidence verification, while MAT addition on unexpired risks reserve is deleted.   Transfer pricing adjustment remanded for fresh evidence verification, while MAT addition on unexpired risks reserve is deleted. Issue Whether transfer pricing adjustment determining ALP as NIL for intra-group services should be remanded to the AO/TPO to verify… Read More »

No Penalty Lies for Non-Reporting of PE-Unrelated Transactions and CIT(A) Cannot Enhance on New Grounds

By | July 15, 2026
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No Penalty Lies for Non-Reporting of PE-Unrelated Transactions and CIT(A) Cannot Enhance on New Grounds Issue Issue I (Section 271AA Penalty): Whether a transfer pricing penalty under Section 271AA for non-reporting of an international transaction is sustainable when the transaction was executed directly by the foreign head office without any effective nexus to its Indian… Read More »