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India has firmly established itself as the go-to-destination for back offices and Global Capability Centres (GCCs), attracting an increasing number of global companies seeking to set up their presence...

Recently, the Finance Minister of India announced the much-anticipated Union Budget 2025. One of the most critical amendments proposed in the Union Budget 2025 is the introduction of a new Transfer Pricing.

The Advance Pricing Agreement (APA) program has been proven to be an effective tool for dispute resolution since its inception in 2012 in India. The 4th Annual Report encapsulating...

We are pleased to present the latest edition of Tax Street – our newsletter that covers all the key developments and updates in the realm of taxation in India and across the globe for the month of September 2021.

Orchid Pharma Ltd. ("OPL"/ "Taxpayer") is a global pharmaceutical company which produces and sells active pharmaceutical ingredients (APIs) and finished dosage forms (FDFs) around the world.

A new era in transfer pricing documentation and reporting has begun.

If Budget speeches were films, Budget 20261 would be the director's cut — fewer special effects, tighter editing, and a clearer narrative. Without resorting to sweeping policy overhauls...

The taxpayer is a resident in India and is mainly engaged in the profession of acting in films, and also acts as a brand ambassador for various products.

The Budget continues the Government's commitment to strengthening India's start-up ecosystem by boosting funding, encouraging innovation and bringing in simplification.

We are pleased to present the latest edition of Tax Street – our newsletter that covers all the key developments and updates in the realm of taxation in India and across the globe for the month of July 2021.

The Income Tax Act, 1961 ("IT Act") contains a specific chapter, namely Chapter X, which deals with special anti-avoidance rules in the form of transfer pricing regulations as applicable to com¬panies entering into related-party transactions.

The Delhi Tribunal's recent ruling in Paul Wurth Italia has reshaped the application of the force of attraction rule under tax treaties, emphasizing that a permanent establishment's mere existence cannot justify taxation of all source-country profits. This decision marks a critical shift toward requiring demonstrable factual and functional nexus between the PE and disputed income, signaling a more restrained interpretation of this contested principle in international taxation.

No transfer pricing adjustment can be made on corporate guarantees issued by an Indian parent company for the benefit of its overseas subsidiary without charging any guarantee fee/ commission.

The Income Tax Appellate Tribunal has recently held that a permanent establishment of a foreign company has to be treated as separate entity for the purpose of transfer pricing.

As the Modi Government 2.0 presents its first budget of the new decade, there have been a lot of deliberations around various measures that may be looked at for providing...

The Union Budget 2024-25, presented on July 23, 2024, is a strategic blueprint designed to enhance India's economic resilience and foster inclusive growth.

The concept of ‘Secondary Adjustment' was introduced in Finance Act 2017 by introducing new Section 92CE in the Indian Income Tax Act to align transfer pricing provisions with international best practices.