Rulings

Jun 13,2018

Mumbai ITAT remits comparability of 2 companies for benchmarking product development services rendered by assessee [engaged in business of import, wholesale trade, manufacture of drug and medicines and research in

Jun 13,2018

AAR rules that the Applicant (a Singaporean MasterCard group company) has a fixed place PE, service PE and dependent agent PE in India under Article 5 of the India Singapore

Jun 13,2018

Delhi ITAT deletes interest adjustment on fully and Compulsory Convertible Debentures (FCCDs) issued by assesse [engaged in the business of manufacture and sale of electrical automobile components] pursuant to search

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Jun 15,2018

ITAT upholds CIT(A)’s deletion of TP-adjustment in respect of corporate guarantee given by assessee to AEs for AY 2012-13; Notes that AO/TPO treated corporate guarantee as an international transaction and

Jun 15,2018

Pune ITAT upholds DRP order quashing re-assessment proceedings initiated against the assessee for AYs 2005-06 and 2006-07; Referring to Form 3CEB disclosure of management service fee received from AE, AO

Jun 15,2018

ITAT rules on comparables selection and various adjustments for assessee providing IT based engineering design services to AE for AY 2010-11; Upholds TPO’s application of export revenue filter, states that “Since,

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AAR: MasterCard Interface Processor and MasterCard Network constitute fixed place PE in India

AAR rules that the Applicant (a Singaporean MasterCard group company) has a fixed place PE, service PE and dependent agent PE in India under Article 5 of the India Singapore

Jun 13,2018

ITAT: Deletes FCCDs interest adjustment sans any incriminating material found during search-proceeding

Delhi ITAT deletes interest adjustment on fully and Compulsory Convertible Debentures (FCCDs) issued by assesse [engaged in the business of manufacture and sale of electrical automobile components] pursuant to search

Jun 13,2018

HC: Upholds Thirumalai Chemicals inclusion as dealing in same product category; Dismisses Revenue’s appeal

Bombay HC dismisses Revenue’s appeal against ITAT’s confirmation of transaction level benchmarking, assessee’s comparable selection and consideration of provisions written back as operating income in respect of manufacturer-assessee for AY

Jun 12,2018

ITAT: IPO an extra-ordinary event, excludes IPO expenses for PLI computation; Remits 2 comparables

Mumbai ITAT remits comparability of 2 companies for benchmarking product development services rendered by assessee [engaged in business of import, wholesale trade, manufacture of drug and medicines and research in

Jun 13,2018

ITAT: Copper manufacturer comparable to assessee's steel business; Product dissimilarity irrelevant under TNMM

Ranchi ITAT rules on comparable selection, corporate guarantee, loan provided by assessee engaged in the business of manufacture of steel, steel wire, wire rods, etc. for AY 2007-08; Regarding assessee's

Jun 12,2018

News

Taxsutra IFA Special: Digital Economy, Dispute Resolution & Blockchain technology dominate 12th edition of Mauritius Conference

International Fiscal Association – Mauritius Branch (IFA) organized its 12th Annual Conference on May 17th and 18th at Sofitel Mauritius L'Impérial Resort

May 24,2018

UN Model Convention 2017 introduces anti-abuse rules, new FTS article; Incorporates BEPS language

United Nation releases 2017 update of the Model Double Taxation Convention between Developed and Developing Countries;  The UN Model Convention

May 18,2018

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