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

Jun 27, 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

Jun 26, 2017

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

Jun 22, 2017

ITAT: Excludes ESOPs but includes unaccounted support services in operating-cost for software services

Bangalore ITAT remits computation of total cost for ALP-determination of software development services for fresh decision for AY 2003-04; Notes that AE provided certain fixed assets on free

Jun 21, 2017

HC: Construes objections dismissed on ground of delay as DRP-direction; Dismisses assessee’s writ

Madras HC dismisses assessee’s writ petition challenging DRP-order (refusing to condone assessee’s delay in filing objections before it) and consequent final assessment order by AO making the TP-adjustment

Jun 20, 2017

HC: Upholds LIBOR on interest-free advances to wholly owned subsidiaries, applies Tata Autocomp ratio

Bombay HC confirms ITAT order directing use of LIBOR + 2% as arm's length interest rate in respect of interest free advances given by assessee to its wholly

Jun 19, 2017