Rulings

Dec 08,2017

Kolkata ITAT dismisses Revenue’s appeal, upholds assessee’s aggregation of IT and ITeS services provided to Associated Enterprises (AEs) under a single composite contract for AY 2010-11; Refers to OECD’s TP

Dec 04,2017

Jaipur ITAT confirms CIT(A)’s deletion of notional interest adjustment in respect of outstanding AE-receivables for assessee (engaged in manufacturing cut and polished diamonds) for AYs 2007-08 to 2009-10; Notes that

Dec 04,2017

Delhi ITAT, in second round of proceedings, rules on selection of comparables by applying filter of ‘wages to sales ratio’ for assessee providing software development services for AY 2006-07; Notes

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Dec 08,2017

Pune ITAT upholds DRP-order permitting assessee’s (manufacturer of three wheeler and automobile parts) use of separate methods to benchmark sale of spares and component transaction after bifurcating it into 3

Dec 08,2017

Delhi ITAT accepts assessee’s adoption of internal-CUP as MAM for benchmarking its provision of project management services to AEs for AY 2009-10; Notes that assessee adopted internal-CUP as AE had

Dec 07,2017

Delhi ITAT sets aside TP adjustment of Rs 51.10 crores made on protective basis on account of Advertising, Promotion & Marketing (“AMP”) expenses incurred by assessee (distributor engaged in trading

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ITAT: Outstanding AE-receivables pre-2012 amendment, not an ‘international transaction’; Deletes TP-adjustment

Jaipur ITAT confirms CIT(A)’s deletion of notional interest adjustment in respect of outstanding AE-receivables for assessee (engaged in manufacturing cut and polished diamonds) for AYs 2007-08 to 2009-10; Notes that

Dec 04,2017

ITAT: Rules on computation of ‘Wages’ and ‘Sales’ component of employee-cost filter

Delhi ITAT, in second round of proceedings, rules on selection of comparables by applying filter of ‘wages to sales ratio’ for assessee providing software development services for AY 2006-07; Notes

Dec 04,2017

HC: Upholds forex-gains treatment as operating item; Rejects Revenue’s Safe- Harbour Rules reliance

Delhi HC dismisses Revenue’s appeal against ITAT-order in respect of assessee providing IT enabled services (ITeS) in infrastructure development and testing etc. for AY 2011-12; Confirms treatment of forex gain/loss

Dec 05,2017

ITAT: Applies Delhi-HC’s Chryscapital ruling over Bombay-HC in Pentair; Remits all comparables

Bangalore ITAT remits the comparability of all comparables back to AO/TPO for deciding afresh for AY 2005-06; Considers Delhi HC’s observation in Chryscapital Investment that mere fact that an entity

Dec 04,2017

ITAT: Excludes 2 functionally-dissimilar companies following Rampgreen HC ruling; Gives directions on PLI-computation

Delhi ITAT excludes 2 companies as comparables for assessee's captive manufacturing activities for AY 2009-10 citing functional dissimilarity; Dismisses the reasoning adopted by DRP/TPO that "some amount of functional dissimilarity

Dec 04,2017

News

India's 50+ reservations on the revised OECD model tax convention

India's 50+ reservations on the revised OECD model tax convention

Nov 27,2017

India relaxes Article 9(2) restriction, to accept all MAP and bilateral APA applications

India relaxes Article 9(2) restriction, to accept all MAP and bilateral APA applications

Nov 27,2017

Govt sets up Tax Force to draft new direct tax legislation

Govt sets up Tax Force to draft new tax code

Nov 22,2017

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