Rulings

Apr 19,2018

Bangalore ITAT holds that acceptance of income returned by AEs in their assessment cannot preclude Revenue from examining ALP in the hands of another party to same transaction, rejects assessee's

Apr 18,2018

Delhi HC rules on assessee’s appeal challenging ITAT’s selection of Modi Care Ltd as standalone comparable under Resale Price Method (RPM) for benchmarking assessee-distributor’s international transaction of purchase of finished

Apr 17,2018

Bangalore ITAT upholds TPO/DRP’s consideration of provision for doubtful debts as non-operating item while computing profit margins of comparable companies for AY 2013-14; Explains that provision for doubtful debts cannot

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Apr 20,2018

Bombay HC rules on comparables selection in assessee’s IT & ITeS segments for AY 2009-10; In IT segment, upholds ITAT’s exclusion of KALS Information Solution on grounds of functional dissimilarity,

Apr 20,2018

Mumbai ITAT rejects DRP’s non-admission of assessee’s (engaged in manufacturing and trading of fibre glass products) additional ground that amount of written off fixed assets should not be considered as

Apr 20,2018

Bombay HC dismisses Revenue’s appeal, upholds ITAT’s application of TNMM as MAM for benchmarking assessee’s export & import transactions for AY 2005-06; Notes that ITAT followed co-ordinate bench ruling in

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ITAT: TP-provisions not applicable once transaction held as sham

Delhi ITAT lays down law on applicability of TP-provisions to admitted bogus/sham transaction revolving around assessee’s purchase of drilling Rig from AE on hire purchase basis and return of the

Apr 17,2018

ITAT: Provision for doubtful debts, a non-operating item; Distinguishes Sony, Kenexa rulings

Bangalore ITAT upholds TPO/DRP’s consideration of provision for doubtful debts as non-operating item while computing profit margins of comparable companies for AY 2013-14; Explains that provision for doubtful debts cannot

Apr 17,2018

ITAT: Revenue can determine assessee's-ALP, despite AE's income acceptance, considering likely base erosion

Bangalore ITAT holds that acceptance of income returned by AEs in their assessment cannot preclude Revenue from examining ALP in the hands of another party to same transaction, rejects assessee's

Apr 19,2018

ITAT: Foreign partnership firm not ‘eligible assessee’ absent TPO’s variation to international transactions

Delhi ITAT quashes final assessment order passed u/s 144C(1) in case of assessee (a foreign partnership firm engaged in distribution of programming services by non-standard television) as not being an

Apr 16,2018

HC: Questions ITAT's selection of standalone comparable despite being conscious of differences, directs re-examination

Delhi HC rules on assessee’s appeal challenging ITAT’s selection of Modi Care Ltd as standalone comparable under Resale Price Method (RPM) for benchmarking assessee-distributor’s international transaction of purchase of finished

Apr 18,2018

News

Google India only reviewing & evaluating services/tools, not developing software, argues Revenue

Revenue Counsel Mr. C. H. Sundar Rao began arguments on disputed classification of one of Google India’s segments as a

Apr 12,2018

Google India a software developer, TPO’s characterization as KPO wrong, argues Mr Khincha

After conclusion of lengthy hearings on the taxability of Google India’s AdWords payments to Google Ireland, ITAT begins hearing for

Apr 11,2018

OECD publishes 14 additional TP-profiles for countries including India, China & Australia

OECD publishes 14 additional transfer pricing (TP) country profiles (for countries including Australia, China, France and India) reflecting the current

Apr 10,2018

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