Rulings

Feb 21,2017

Mumbai ITAT deletes TP-addition of Rs. 5.53 Cr on purchase of intangible assets (Trademarks, Customer lists and Goodwill) by assessee consequent to acquisition of credit card processing and merchant banking

Feb 21,2017

Delhi ITAT attributes 30% of profits to Indian branch (PE) of Singapore-based assessee (engaged in trading of medical equipment) in respect of direct sales in India by head office during

Feb 17,2017

Chennai ITAT dismisses assessee’s appeal challenging TP-adjustment towards notional interest on receivables outstanding from AE beyond 90 days; Rejects assessee’s arguments that it was a debt free company and profit

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Feb 20,2017

ITAT rejects Revenue’s contention against exclusion of Infosys and FCS Software Limited holding that software product companies cannot be equated with software development service provider assessee, upholds inclusion of 3

Feb 20,2017

ITAT dismisses assessee’s appeal for exclusion of ‘Bodhtree Consulting Ltd’ for AY 2009-10; Rejects assessee’s reliance on Infinera India ruling in which Bodhtree Consulting Ltd was excluded on the ground

Feb 20,2017

ITAT accepts assessee’s contention to exclude 5 functionally dissimilar companies citing  reasons like intangible ownership, brand, high end services like KPO and outsourcing of activity; Further, directs TPO to examine

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ITAT: Upholds TP-adjustment on outstanding AE-receivables considering ‘potential loss’ of income to assessee

Chennai ITAT dismisses assessee’s appeal challenging TP-adjustment towards notional interest on receivables outstanding from AE beyond 90 days; Rejects assessee’s arguments that it was a debt free company and profit

Feb 17,2017

ITAT: Prefers RPM over CUP/TNMM for benchmarking Swarovski’s crystal imports; Remits AMP issue

Delhi ITAT rejects CUP method applied by Swarovski India (assessee) for benchmarking combined international transaction of ‘Import of Crystal goods and Crystal components’, directs application of Resale Price Method (RPM);

Feb 15,2017

ITAT: Approves assessee’s change of MAM before CIT(A), considers subsequent data availability

Pune ITAT rules that assessee is not precluded from changing most appropriate method (MAM) from CPM adopted in TP study to CUP method before CIT(A), dismisses Revenue’s appeal; Assessee (manufacturer

Feb 16,2017

ITAT: Excludes 4 comparables citing functional dissimilarity, turnover filter and Intangible ownership

ITAT rules on comparable selection for assessee's software development services for AY 2009-10; Upholds assessee's contention for rejection of 4 comparables citing reasons like functional dissimilarity, huge turnover, ownership of

Feb 15,2017

ITAT: Deletes adjustment on AMP expenses and export of foreign currency; Follows earlier order

ITAT deletes TP-adjustment on AMP spend following earlier year’s order and ruling in case of Bausch & Lomb Eyecare, holds that AMP spend not an international transaction absent existence of 'agreement'

Feb 15,2017

News

Public CbCR to require qualified majority rather than unanimity : European Parliament

European Parliament’s Committee on Legal Affairs issues public opinion on legal basis of EC proposal relating to public Country-by-Country (CbC)

Feb 20,2017

Australian Govt tables DPT Bill to combat multinational tax-avoidance, proposes incorporating final BEPS Actions 8-10

Australian Government introduces Treasury Laws Amendment (Combating Multinational Tax Avoidance) Bill 2017 in the Parliament consisting of 3 significant proposals to

Feb 14,2017

Soli Dastur focuses on 'grey' areas in annual Budget lecture

In a lecture organized by Bombay Chartered Accountants Society (BCAS) yesterday in Mumbai, while ​discussing direct tax proposals of Budget 2017, the tax

Feb 08,2017

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