Rulings

Dec 12,2018

SC upholds HC-order confirming ITAT’s deletion of TP-adjustment on guarantee fee amounting to Rs.11.51 Cr for AY 2008-09; HC had accepted guarantee commission fee charged by assessee to its AEs at 0.53%

Dec 11,2018

Mumbai ITAT upholds Pr. CIT’s order u/s 263 for AY 2015-16, confirms AO’s assessment order to be erroneous & prejudicial to Revenue’s interest absent AO’s reference of TP matter to

Dec 07,2018

Mumbai ITAT rejects assessee’s (engaged in the business of outdoor media advertising services) Nil ALP-determination of loans granted to AEs on the basis that their recovery was doubtful owing to

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Dec 12,2018

Bombay HC dismisses Revenue’s appeal against ITAT order quashing assessment order passed without first forwarding draft order to assessee and holding that a subsequent corrigendum cannot correct the mistake; Refers

Dec 11,2018

Mumbai ITAT sets aside CIT(A)’s order, remits issue of computation of profit level indicator (PLI) for benchmarking assessee’s international transactions involving payment of marketing service fees back to AO for

Dec 11,2018

Kolkata ITAT sets aside CIT(A)’s cryptic order deleting TP-adjustment in case of assessee (providing Steel Detailing Services) without giving AO/TPO an opportunity to offer comments for AYs 2010-11 & 2011-12; Notes that

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ITAT: Rejects assessee's Nil interest-ALP for stressed AE-loans citing commercial expediency, revenue neutrality

Mumbai ITAT rejects assessee’s (engaged in the business of outdoor media advertising services) Nil ALP-determination of loans granted to AEs on the basis that their recovery was doubtful owing to

Dec 07,2018

ITAT: TPO cannot arbitrarily interfere with PLI-selection; Sec 41(1)-waiver irrelevant for intra-group services benchmarking

Delhi ITAT rules on selection of comparables, MAM, PLI and grant of capacity adjustment in manufacturing segment of assessee (engaged in manufacturing products to be assembled in the manufacturing of

Dec 06,2018

ITAT: Upholds Sec 263-order absent AO’s mandatory TPO-reference as per CBDT Circular 3/2016

Mumbai ITAT upholds Pr. CIT’s order u/s 263 for AY 2015-16, confirms AO’s assessment order to be erroneous & prejudicial to Revenue’s interest absent AO’s reference of TP matter to

Dec 11,2018

HC: Corrigendum can’t correct draft order non-issuance; Assessee not estopped from challenging AO’s jurisdiction

Bombay HC dismisses Revenue’s appeal against ITAT order quashing assessment order passed without first forwarding draft order to assessee and holding that a subsequent corrigendum cannot correct the mistake; Refers

Dec 12,2018

SC: Upholds HC-order confirming deletion of guarantee fee TP-adjustment for Glenmark Pharma

SC upholds HC-order confirming ITAT’s deletion of TP-adjustment on guarantee fee amounting to Rs.11.51 Cr for AY 2008-09; HC had accepted guarantee commission fee charged by assessee to its AEs at 0.53%

Dec 12,2018

News

Australia releases draft practical compliance guideline addressing TP-issues for inbound distribution arrangements

Australian Taxation Office (‘ATO’) releases draft practical compliance guideline addressing transfer pricing (TP) issues related to inbound distribution arrangements; The

Nov 30,2018

EU Joint TP Forum outlines 10 key recommendations on coordinated approach to TP-controls

EU Joint TP Forum releases a Report on coordinated approach to TP-controls within EU; Report, consisting of 10 key recommendations,

Nov 29,2018

CBDT outlines recommended approaches to deal with rulings exchanged under BEPS Action 5

CBDT’s FT&TR division releases guidance on 5 types of rulings received from other jurisdictions under BEPS Action 5; The guidance

Nov 28,2018

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