Rulings

Jan 18,2017

Mumbai ITAT rejects TPO/DRP's approach of making adhoc adjustment of 3%/8% towards differences between assessee's contract manufacturing activity for AE and sales made to non- AEs under internal TNMM, observes that such

Jan 17,2017

Bangalore ITAT upholds CIT(A) order considering 3 companies namely Multitrade Overseas INC, Harris Freeman & Co. LP) and Southern Tea LLC as associate enterprises of the assessee; Rejects assessee’s contention

Jan 16,2017

Mumbai ITAT upholds CIT(A) order for AY 2006-07 deleting TP addition on buy-back of equity shares of its wholly owned subsidiary in US by re-characterizing the investment transaction as loan;

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Jan 19,2017

ITAT dismisses Revenue’s appeal against granting adjustment for accelerated depreciation and against exclusion of VoltAmp Transformers from comparables list; Upholds DRP’s direction to AO to work out assessee’s Profit Level

Jan 19,2017

ITAT directs exclusion of 8 companies from the final list of comparables while benchmarking software development services rendered by assessee to its AEs during AY 2009-10; 7 companies excluded following

Jan 18,2017

Delhi ITAT remits comparability of foreign companies to CIT(A) for fresh adjudication in case of watchmaker Timex Group India Ltd, directs CIT(A) to seek remand report from AO/TPO in respect of foreign

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ITAT: Upholds entity-level TNMM for R&D & management fee absent reliable comparable under CUP

Chennai ITAT upholds TNMM adopted by assessee over CUP method for benchmarking payment to AE towards Research and Development (R&D) and management fees for AYs 2009-10, 2010-11 and 2011-12; TPO

Jan 12,2017

ITAT: Upholds TP-adjustment deletion on buy-back of shares, rejects investment re-characterization as loan

Mumbai ITAT upholds CIT(A) order for AY 2006-07 deleting TP addition on buy-back of equity shares of its wholly owned subsidiary in US by re-characterizing the investment transaction as loan;

Jan 16,2017

ITAT: Upholds AE-relationship between family-owned entities; Sec. 92C-proviso benefit allowable on coffee board prices

Bangalore ITAT upholds CIT(A) order considering 3 companies namely Multitrade Overseas INC, Harris Freeman & Co. LP) and Southern Tea LLC as associate enterprises of the assessee; Rejects assessee’s contention

Jan 17,2017

ITAT: Holds TPO/DRP's order as non-speaking; Adhoc adjustments towards functional differences, against TP-concept

Mumbai ITAT rejects TPO/DRP's approach of making adhoc adjustment of 3%/8% towards differences between assessee's contract manufacturing activity for AE and sales made to non- AEs under internal TNMM, observes that such

Jan 18,2017

ITAT: Winding-up of dormant subsidiary not ‘extraordinary event’ impacting profits; Rejects comparable exclusion

ITAT rejects assessee’s plea for exclusion of 2 comparables on grounds of extraordinary event and functional dissimilarity while benchmarking provision of KPO engineering services/ IT enabled Services (ITeS) to AEs

Jan 13,2017

News

Singapore provides TP-documentation exemption for related-party loans adhering to 'indicative margins'

Singapore IRAS publishes fourth edition of its e-Tax Guide on transfer pricing, updates guidance on arm’s length principle and functional

Jan 17,2017

Eye Share : Handpicked Transfer Pricing rulings of 2016

The year 2016 will be remembered for a mixed bag of various milestone and controversial TP rulings. The Indian courts

Jan 17,2017

CBDT's year-end review highlights CbCR implementation and achievements in APA/MAP resolutions

CBDT publishes Year End Review – 2016 showcasing major achievements during current financial year 2016-17 so far; On the transfer

Jan 10,2017

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