Rulings

Jun 27,2017

Bangalore ITAT rules on selection of comparables in assessee’s software development & ITeS segments for AY 2012-13, applies 10 times turnover range over Rs 1-200cr turnover filter for selection of

Jun 26,2017

Bangalore ITAT sets aside CIT (A)’s order for AYs 2009-10 and 2010-11, restores matter back to TPO for fresh adjudication; Notes that in both AYs, assessee’s case was referred to

Jun 22,2017

Delhi ITAT upholds interest adjustment on delayed AE-receivables for assessee (engaged in executing engineering design and drawing for AEs) for AY 2012-13; Distinguishes assessee’s reliance on co-ordinate bench ruling in assessee’s

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Jun 28,2017

ITAT, in second round of appeal, rules on correctness of computation of operating margin of comparables, working capital adjustment & risk adjustment by TPO in set-aside proceedings for AY 2007-08; Upholds

Jun 28,2017

Pune ITAT rules on multiple TP-issues in case of assessee’s manufacturing (of resistors and capacitors) segment and ITeS segment for AY 2008-09, follows co-ordinate bench ruling in assessee’s own case in

Jun 28,2017

ITAT remits comparability of Coral Hubs Ltd (formerly known as Vishal Information Technologies Ltd.) in case of ITeS-provider assessee for AY 2010-11; Notes that Coral Hubs outsourced major part of

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ITAT: Upholds interest adjustment on delayed AE-receivables; Distinguishes earlier order in own case

Delhi ITAT upholds interest adjustment on delayed AE-receivables for assessee (engaged in executing engineering design and drawing for AEs) for AY 2012-13; Distinguishes assessee’s reliance on co-ordinate bench ruling in assessee’s

Jun 22,2017

ITAT: TPO-reference for < Rs 15 Crores cases not bad in law; Remands issue for AYs 2009-10,2010-11

Bangalore ITAT sets aside CIT (A)’s order for AYs 2009-10 and 2010-11, restores matter back to TPO for fresh adjudication; Notes that in both AYs, assessee’s case was referred to

Jun 26,2017

ITAT: Turnover filter relevant for service sector, draws support from Safe Harbour Rules

Bangalore ITAT rules on selection of comparables in assessee’s software development & ITeS segments for AY 2012-13, applies 10 times turnover range over Rs 1-200cr turnover filter for selection of

Jun 27,2017

ITAT: Deletes TP-adjustment on royalty payment; Remits TP-addition on inflated purchases following earlier-order

Delhi ITAT upholds CIT(A)’s order deleting adjustment in respect of royalty payments in AY 2007-08 and 2008-09 by assessee (engaged in the business of manufacturing of auto parts and components)

Jun 26,2017

ITAT: Manpower underutilization linked to capacity adjustment; Rejects modification to ITAT-order remitting issue

Bangalore ITAT partly allows assessee’s miscellaneous petition, modifies ITAT order pertaining to AY 2006-07 to exclude Mega Soft Ltd as a comparable in place of Lanco Global Solutions Ltd applying

Jun 23,2017

News

OECD to publish Transfer Pricing Guidelines next week

OECD to publish Transfer Pricing Guidelines for Multilateral Enterprises and Tax Administrations next week : OECD tweet

Jun 27,2017

IT Department's 2016 internal guidance on AMP draws heavily from BEPS approach

IT Dept.'s internal Guidance to TPOs on marketing intangible adjustment (issued in second half of 2016) relies extensively on BEPS Guidance

Jun 22,2017

CBDT notifies rules for computation of interest income pursuant to secondary adjustments

CBDT notifies Rule 10CB for computation of interest income pursuant to secondary adjustments; Imputed interest to be calculated based on

Jun 16,2017

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