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

In the dynamic world of tax law, determining eligibility for deductions under Section 10A and applying transfer pricing regulations often lead to disputes. The recent ruling in CIT-I vs. Birlasoft Ltd. by the Delhi High Court sheds