Rulings

Aug 23,2017

Bangalore ITAT directs CIT(A) to decide whether the profit margin under USA MAP needs to be applied to non-USA transactions in case of ITeS provider for AY 2004-05; Assessee had

Aug 23,2017

Delhi ITAT rules that Forex gain on AE-receivables on account of services rendered by assessee (captive service provider designing transformer components etc. under the projects provided by AE) should be

Aug 22,2017

Delhi ITAT upholds CIT(A)’s adoption of TNMM for benchmarking assessee’s import & export transactions for AY 2002-03; Notes that TPO had first applied TNMM on assessee’s entire turnover to propose

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Aug 23,2017

Delhi ITAT allows assessee's appeal challenging TP-adjustment towards notional interest on receivables from AE in respect of assessee providing data warehousing solutions for AY 2012-13; TPO had re-characterized AE-receivable as

Aug 23,2017

Bangalore ITAT dismisses, as not pressed, assessee’s stay petition seeking stay on collection of outstanding demand of Rs 6.12 cr for AY 2011-12 on August 11, 2017; Considers assessee’s submission

Aug 23,2017

Delhi ITAT upholds CIT(A)’s order deleting TP-adjustment for AYs 2007-08 and 2008-09 on Indian subsidiary of Japanese Sogo Shosha entity in respect of business support services provided to AEs regarding sourcing of goods

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ITAT: Characterizes operational outsourcing services as low-end ITeS; Refers to Safe Harbour Rules

Delhi ITAT characterizes assessee’s operational outsourcing services to AE as low-end ITeS for AY 2012-13, refers to the definition of ITeS under the Safe Harbour Rules (‘SHR’) to establish that

Aug 17,2017

ITAT: Non-availing entire gamut of AE-services cannot be basis for rejecting TP-study

Mumbai ITAT holds that no TP-adjustment can be made if an assessee avails only certain services out of the bunch of services mentioned in an agreement, especially when TPO does

Aug 21,2017

ITAT: Includes ‘Kals’, ‘Accel Transmatics’ considering segmental data availability; Distinguishes precedents

Bangalore ITAT rules on selection of comparables for assessee providing software development services to AE for AY 2006-07; Rejects assessee’s plea to exclude ‘Aztec Software Systems’ & ‘Megasoft’ on the

Aug 18,2017

ITAT: Upholds TNMM; Applying different methods for inter-connected import & export transactions inappropriate

Delhi ITAT upholds CIT(A)’s adoption of TNMM for benchmarking assessee’s import & export transactions for AY 2002-03; Notes that TPO had first applied TNMM on assessee’s entire turnover to propose

Aug 22,2017

HC: AO cannot make disallowance in final order beyond draft order variations/ DRP-enhancement

Madras HC confirms ITAT order for AY 2009-10, holds that AO exceeded the jurisdiction by making new disallowance while passing order u/s 144C(13) giving effect to DRP directions when such

Aug 18,2017

News

UK updates CbCR Manual, restricts data usage to 'high level' TP risk assessment

UK HMRC updates ‘International Exchange of Information Manual’ [providing guidance on country-by-country (CbC) reporting format for multinationals] in light of

Aug 16,2017

US Tax Court holds cancellation of APAs by IRS as abuse of discretion

US tax Court holds that cancellation of APAs (entered with Eaton Corporation and Subsidiaries, ‘taxpayer’) by IRS was an abuse

Aug 04,2017

India notifies MCAA for automatic exchange of CbCR

India notifies Multilateral Competent Authority Agreement (MCAA) for automatic exchange of Country by Country Reports (CbCR); MCAA was signed by

Jul 31,2017

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