ITAT: Applies USA MAP resolution representing 93% turnover to non-USA transaction

ITAT accepts taxpayer's plea to apply outcome of MAP resolution with USA (representing 93% of the ITeS segment's turnover) to the balance 7% transactions with non-USA AEs for

Jul 12, 2018

ITAT: Deletes Johnson & Johnson's TP disallowance for royalty and technical services payments, follows precedents

ITAT deletes TP disallowance for AY 2003-04 towards payment of royalty on traded finished goods made by the assessee to Johnson & Johnson USA; Follows coordinate bench ruling

Jul 12, 2018

ITAT: Deletes TP adjustment on 'alleged' overdue receivables; Relies on GSS Infotech ruling

ITAT deletes transfer pricing adjustment in respect of receivables for AY 2013-14; TPO noted the normal credit period of 30 days and after allowing 30 grace days,TPO computed

Jul 12, 2018

ITAT: Upholds rejection of aggregating management fees payment transaction under TNMM

ITAT sets aside CIT(A)'s order upholding the TP addition of Rs 97 lakhs on payment of management fees for AY 2008-09; TPO and CIT(A) had rejected assessee's aggregation

Jul 12, 2018

ITAT: Finds merit in assessee’s manpower-supplier classification over TPO’s software-developer plea; Remits issue

ITAT remits functional classification of services rendered by assessee to AE for AY 2013-14; Notes that AO/DRP had considered nature of services rendered by assessee as software development

Jul 12, 2018

ITAT: Excludes 3 comparables for software development and marketing support service provider

Bengalore ITAT adjudicates on comparable selection for assessee’s software development services and marketing support services segment for AY 2010-11; Accepts R S Software as comparable considering both parties

Jul 12, 2018