Rulings

May 23,2017

Delhi ITAT remands question of existence of international transaction involving AMP expenses for AYs 2006-07, 2007-08 & 2008-09 in second round of appeal; Notes that in first round of appeal

May 22,2017

Bombay HC upholds ITAT order deleting TP-addition on account of royalty payment for technical know-how made by assessee to AE for AY 2008-09, dismisses Revenue’s appeal; Follows co-ordinate bench ruling

May 19,2017

Delhi ITAT upholds deletion of TP-adjustment on account of brand promotion expenses incurred by assessee engaged in blending, bottling and trading of Indian Made Foreign Liquor (‘IMFL’) during AYs 2004-05

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May 24,2017

ITAT remits AMP-adjustment back to TPO to determine whether incurrence of AMP-expenditure is an international transaction for assessee engaged in the business of manufacturing confectionary products for AY 2011-12; Notes

May 24,2017

ITAT rules on selection of comparables for assessee providing software development services to AE for AY 2011-12; Excludes 11 comparables on various grounds such as functional dissimilarity, absence of segmental

May 24,2017

ITAT partly allows assessee’s appeal for AY 2012-13, remits working capital adjustment issue back to AO / TPO noting assessee’s positive working capital in balance sheet; Directs AO / TPO

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ITAT: Upholds AMP-adjustment deletion for liquor manufacturer; AE can’t benefit from India specific brands

Delhi ITAT upholds deletion of TP-adjustment on account of brand promotion expenses incurred by assessee engaged in blending, bottling and trading of Indian Made Foreign Liquor (‘IMFL’) during AYs 2004-05

May 19,2017

HC: Confirms TP-adjustment deletion on technical knowhow royalty; Admits appeal on other royalty issues

Bombay HC upholds ITAT order deleting TP-addition on account of royalty payment for technical know-how made by assessee to AE for AY 2008-09, dismisses Revenue’s appeal; Follows co-ordinate bench ruling

May 22,2017

ITAT: Corporate guarantee not international transaction prior to Sec 92B amendment, applies Siro Clinpharm ratio

Hyderabad ITAT rules that corporate guarantee provided by assessee on behalf of its AEs in USA during AY 2011-12 were not ‘international transactions’ prior to the amendment to Sec 92B

May 18,2017

ITAT: Remands AMP-issue despite HC's refrain, considers assessee's plea for in-depth analysis

Delhi ITAT remands question of existence of international transaction involving AMP expenses for AYs 2006-07, 2007-08 & 2008-09 in second round of appeal; Notes that in first round of appeal

May 23,2017

HC: Invalidates AO’s final assessment sans draft order, Sec 144C non-compliance not ‘curable defect’

Delhi HC allows assessee’s writ for AYs 2007-08 and 2008-09, sets aside final assessment order passed by AO without first issuing draft assessment order as mandated by Sec 144C(1); Observes

May 23,2017

News

Australia issues draft risk-based compliance guideline for related party financing arrangements

Australian Taxation Office (‘ATO’) issues a draft practical compliance guideline which sets out its administration approach in respect of cross-border

May 24,2017

OECD releases discussion draft on hard-to-value intangibles, covering non-BEPS portion

OECD releases discussion draft providing guidance on implementation of approach to pricing transfers of hard-to-value intangibles (‘HTVI’), described in Chapter

May 23,2017

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