Rulings

Oct 17,2017

Delhi ITAT remits AMP-adjustment for assessee (engaged in retailing business) for AY 2012-13 following co-ordinate bench ruling in assessee’s own case for AY 2010-11, directs AO/TPO to determine whether there exists an international

Oct 16,2017

Delhi ITAT restores entire TP issue back to TPO for assessee (engaged in manufacturing and trading of various automotive and aluminum brake and aluminum components) for AY 2010-11; Notes that

Oct 13,2017

Pune ITAT rejects adoption of CUP-method for benchmarking inter-alia import of raw materials/consumables/machinery by assessee (engaged in manufacturing of wiring harnesses for the automotive industry) for AY 2005-06, upholds TPO/CIT(A)’s

View More

Oct 17,2017

Bangalore ITAT restores TP issue for AY 2006-07 back to AO/TPO, directs adoption of TNMM; Notes that in earlier order, ITAT had directed adoption of TNMM, thus holds that "we

Oct 17,2017

Mumbai ITAT remits TP-adjustment in assessee’s ITeS segment for adjudicating the issue afresh in terms of resolution reached under MAP agreement for AY 2010-11; Considers assessee’s submission that the issue

Oct 17,2017

Bangalore Tribunal dismisses miscellaneous petition filed by Revenue in case of Brocade Communications Systems P Ltd for AY 2010-11 citing delay in filing; Referring to provisions of Sec. 254(2) which provides for filing

View More

HC: ITAT’s remand to AO unwarranted when relevant facts on TP-issue available on record

Delhi HC, in second round of proceedings, rules that ITAT erred in remanding the matter back to AO regarding ALP-determination of intra-group services payment by assessee (engaged in the business

Oct 12,2017

ITAT: Rejects aggregation approach for intra-group services of diverse nature; Applies Knorr-Bremse ratio

Delhi ITAT upholds rejection of aggregation approach adopted by assessee (engaged in exploring and drilling, producing, refining and marketing of minerals, oils and related by-products) for benchmarking receipt of intra-group

Oct 12,2017

ITAT: Rejects assessee's CUP method based on ‘proposed price’ for imports, upholds TNMM

Pune ITAT rejects adoption of CUP-method for benchmarking inter-alia import of raw materials/consumables/machinery by assessee (engaged in manufacturing of wiring harnesses for the automotive industry) for AY 2005-06, upholds TPO/CIT(A)’s

Oct 13,2017

ITAT: Rejects adjustment on standalone comparable basis; TPO to seek comparable information u/s 133

Delhi ITAT restores entire TP issue back to TPO for assessee (engaged in manufacturing and trading of various automotive and aluminum brake and aluminum components) for AY 2010-11; Notes that

Oct 16,2017

ITAT: Excludes ‘Infosys-BPO’, ‘Accentia’ for ITeS provider citing extraordinary financial events; Follows precedents

Pune ITAT rules on selection of comparables for assessee rendering ITeS/BPO services to AE for AY 2010-11; Accepts assessee’s plea for exclusion of Infoys BPO Ltd considering its brand value,

Oct 12,2017

News

OECD: 1000+ automatic exchange relationships active for CbCR; USA signs 27 bilateral agreements

OECD releases CbC reporting implementation status and exchange relationships between tax administrations and updated about the activations of automatic exchange relationships under the

Oct 12,2017

Experts react to draft CbCR-rules; Rajat Bansal says rules in line with BEPS Action 13

The prolonged wait is finally over. Nearly 18 months after legislating the adoption of Country-by-Country Reporting (CbCR) for multinationals, CBDT

Oct 10,2017

CBDT proposes consolidated group revenue & international transaction value dependent threshold for Master-File

CBDT proposes insertion of Rule 10DA, 10DB and Forms 3CEBA to 3CEBE in Income-tax Rules 1962, laying down guidelines for

Oct 06,2017

View More

Top

Resource Center

Gain access to insightful resources, carrying useful observations on relevant issues!

Around The World

Get transfer pricing updates from around the world.