ITAT: Upholds risk-adjustment denial in second appeal round; Remits operating margin, working-capital computation

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

Jun 28, 2017

ITAT: Rejects PBDIT as PLI but permits depreciation rate difference adjustment, follows precedent

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

Jun 28, 2017

ITAT: Remits comparability of Coral-Hubs to consider Rampgreen HC-ruling not available before CIT(A)

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

Jun 28, 2017

ITAT: ALP cannot be ‘Nil’ where CUP is MAM; Remits intra-group services ALP-determination

Delhi ITAT restores ALP-determination in respect of payments for technology support services, back-end service charges, shared cost for co-located premises & loan processing fees by assessee (non-banking finance

Jun 28, 2017

ITAT: Restores TP-adjustment w.r.t. technical, management service fee to AO/TPO; Follows earlier-order

Chennai ITAT restores TP-adjustment in respect of payment of technical and management service fee by assessee (engaged in manufacturing automobile seats) to its Korean AE for AY 2012-13; Notes

Jun 27, 2017

ITAT: Remands comparability of 13 companies for fresh adjudication considering CIT(A)’s cryptic, non-speaking order

ITAT remands comparability of 13 companies for ABB Industrial IT Development Centre for AY 2004-05 in light of CIT(A)’s cryptic & non-speaking order; Notes that CIT(A) had rejected

Jun 27, 2017

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