Introduction The Government has introduced critical amendments to transfer pricing regulations aimed at streamlining the process of determining Arm’s Length Price (ALP) while reducing excessive compliance burdens. These new provisions establish a multi-year ALP determination framework, eliminating

The concept of a Permanent Establishment (PE) plays a pivotal role in international taxation, especially in determining tax liabilities for foreign enterprises operating in another country. In the case of Pr. CIT vs. Samsung Electronics Co. Ltd.,

Transfer pricing regulations have always been a cornerstone of ensuring fair taxation in transactions between related parties. With the omission of Clause (i) of Section 92BA by the Finance Act, 2017, questions arose regarding its applicability to

Transfer pricing disputes often revolve around complex issues, such as imputing interest on outstanding receivables in international transactions. The recent ruling in Ramboll India Pvt. Ltd. vs. ACIT by the Income Tax Appellate Tribunal (ITAT), Delhi, provides