Rulings

Jun 20,2018

Madras HC dismisses Revenue's writ appeal against the order of Single Judge for AY 2009-10 holding the final assessment order passed, without issuing draft order, and the subsequent corrigendum treating

Jun 20,2018

Kolkata ITAT upholds CIT(A)’s acceptance of assessee’s TNMM over TPO’s CUP-method for benchmarking assessee’s (manufacturer in FMCG Industry) sale of finished goods transaction for AY 2012-13; Noting that prices at which

Jun 13,2018

Mumbai ITAT remits comparability of 2 companies for benchmarking product development services rendered by assessee [engaged in business of import, wholesale trade, manufacture of drug and medicines and research in

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Jun 20,2018

Delhi ITAT remits ALP determination in case of assessee providing business development, advisory and other support services to Boeing Group for AY 2009-10 ; Directs re-examination of comparability of 3 government companies,

Jun 20,2018

Delhi ITAT rules on selection of comparables for assessee providing call center services to AE for AY 2010-11; Rejects Revenue’s plea for inclusion of Infosys BPO on grounds of functional

Jun 19,2018

ITAT remits ALP-determination of notional interest on advances made to AE for AY 2009-10; Notes that assessee had not charged any interest on advances and claimed that advances were made

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HC: Upholds Single Judge order; Corrigendum cannot cure failure to pass 'draft order' u/s 144C

Madras HC dismisses Revenue's writ appeal against the order of Single Judge for AY 2009-10 holding the final assessment order passed, without issuing draft order, and the subsequent corrigendum treating

Jun 20,2018

ITAT: Allows capacity utilization adjustment for engineering design provider considering Parent Co’s bankruptcy

ITAT rules on comparables selection and various adjustments for assessee providing IT based engineering design services to AE for AY 2010-11; Upholds TPO’s application of export revenue filter, states that “Since,

Jun 15,2018

ITAT: Upholds TP-adjustment deletion on corporate guarantee; Follows earlier order

ITAT upholds CIT(A)’s deletion of TP-adjustment in respect of corporate guarantee given by assessee to AEs for AY 2012-13; Notes that AO/TPO treated corporate guarantee as an international transaction and

Jun 15,2018

ITAT: Rejects TPO's CUP sans adjustment for different geographies, customer preference & market strategy

Kolkata ITAT upholds CIT(A)’s acceptance of assessee’s TNMM over TPO’s CUP-method for benchmarking assessee’s (manufacturer in FMCG Industry) sale of finished goods transaction for AY 2012-13; Noting that prices at which

Jun 20,2018

ITAT: Deletes interest on delayed AE-receivables; Follows Pegsystems, Kusum Healthcare rulings

Hyderabad ITAT deletes interest adjustment made on assessee’s [engaged in software development services] outstanding AE-receivables for AY 2011-12; TPO observing considerable delay in realization of receivables from its AE charged

Jun 14,2018

News

CBDT proposes amending repatriation time-limit for secondary adjustment in APA/MAP cases

CBDT releases draft notification proposing to amend Rule 10CB of the Income Tax Rules, 1962 regarding computation of interest income

Jun 20,2018

Taxsutra IFA Special: Digital Economy, Dispute Resolution & Blockchain technology dominate 12th edition of Mauritius Conference

International Fiscal Association – Mauritius Branch (IFA) organized its 12th Annual Conference on May 17th and 18th at Sofitel Mauritius L'Impérial Resort

May 24,2018

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