Rulings

Feb 23,2018

Delhi ITAT, in second round of proceedings, remits AMP-issue for Motorola Solutions back to AO/TPO for determining ALP afresh for AY 2007-08; Notes that ITAT, in first round of proceedings,

Feb 20,2018

Delhi ITAT, in second round of proceedings, dismisses assessee’s appeal against AO’s final assessment order (passed without a draft assessment order) as non-maintainable for AY 2012-13, holds that appropriate remedy

Feb 20,2018

Delhi ITAT upholds TPO’s aggregation of ITES and software development services (SDS) for benchmarking under TNMM absent assessee’s substantiation for bifurcation of the segments for AY 2013-14; Observes that assessee

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Feb 23,2018

Delhi ITAT dismisses assessee's TP-ground for AY 2009-10 relating to adjustment on royalty and franchise fee, as withdrawn, in view of resolution under MAP; However, regarding disallowance of foreign exchange loss

Feb 22,2018

Delhi ITAT restores issue of levy of concealment penalty u/s 271(1)(c) back to file of AO in case of NDTV for AY 2007-08; Notes that Tribunal, in quantum appeal, vide order dated

Feb 22,2018

Bangalore ITAT grants extension of stay of demand to Manipal Global Education Services up to March 31, 2018 for AY 2010-11; Notes that “existence of all conditions for grant of stay has already been considered by the Tribunal

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ITAT: Dismisses appeal against final assessment post-remand as non-maintainable, guides assessee to CIT(A)/HC

Delhi ITAT, in second round of proceedings, dismisses assessee’s appeal against AO’s final assessment order (passed without a draft assessment order) as non-maintainable for AY 2012-13, holds that appropriate remedy

Feb 20,2018

ITAT: Upholds TPO’s aggregation of ITES, software segments; Deviates from earlier years' approach

Delhi ITAT upholds TPO’s aggregation of ITES and software development services (SDS) for benchmarking under TNMM absent assessee’s substantiation for bifurcation of the segments for AY 2013-14; Observes that assessee

Feb 20,2018

ITAT: Decides appeal ex-parte absent representation by assessee; Confirms CIT(A)’s-order on TP-issues

Bangalore ITAT dismisses assessee’s appeal challenging TP-adjustments in respect of corporate guarantee, loan, outstanding receivables etc. for AYs 2011-12 & 2013-14; Noting that none appeared on behalf of assessee despite

Feb 19,2018

ITAT: Grants stay to Citrix R&D considering 50% demand already discharged

Bangalore ITAT grants stay of demand of Rs. 7.54cr to Citrix R&D India till March 31, 2018 or till appeal disposal, whichever is earlier, for AY 2012-13; Notes that demand arose due to TP-adjustment made

Feb 19,2018

ITAT: Excludes 2 comparables on functional dissimilarity for software developer; Includes Evoke Technologies

Hyderabad ITAT rules on comparables selection for assessee’s software development for AY 2011-12; Accepts assessee’s contentions to exclude Persistent Systems Ltd and Sasken Communication Technologies Ltd on ground of functional

Feb 21,2018

News

Indian TP Evolution - How have the last 10 Union Budgets shaped TP policies?

India is emerging as the new ‘global economic hotspot’ according to the International Monetary Fund. For this purpose, it is

Feb 23,2018

UK 's MAP-policy paper expresses willingness to consider interest deduction pursuant to secondary adjustment

UK HMRC releases Statement of Practice (‘SoP’) on Mutual Agreement Procedure (‘MAP’) to set out UK’s practice regarding methods to reduce/prevent

Feb 21,2018

KPMG Transfer Pricing Head Rahul Mitra resigns, likely to join Dhruva Advisors

KPMG India Transfer Pricing Head Rahul Mitra resigns, likely to join Dhruva Advisors : Sources

Feb 12,2018

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