Rulings

Dec 05,2016

SC admits Revenue’s SLP against Punjab and Haryana HC ruling for AY 2009-10 wherein HC had upheld ITAT’s powers to grant stay beyond 365 days; HC had noted that the third proviso

Dec 05,2016

Chennai ITAT rejects assessee's contention that assessment order passed u/s 144(13) on 26.02.2015 (passed in second round of proceedings pursuant to ITAT remand back) was barred by limitation despite AO

Dec 02,2016

Chennai ITAT upholds AO's action of directly issuing the assessment order u/s 143(3) without issuing a draft assessment order u/s 144C despite assessee being an ‘eligible assessee’ (i.e. a foreign company) u/s

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Nov 30,2016

ITAT admits additional ground, holds that in view of Special Bench ruling in Quark Systems assessee can raise additional ground to seek exclusion of comparable selected by it or not

Nov 30,2016

Chennai ITAT remits TP-issues relating to interest free loan and guarantee commission to AO / TPO for AY 2011-12; In respect of interest free loan advanced by assessee to its

Nov 29,2016

ITAT excludes two companies from the list of comparables in respect of assessee providing support services to its AEs in connection with research and development during AY 2008-09; Excludes Celestial

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ITAT: Explains 'influence' u/s 92A(2)(i), distribution partners not 'deemed AE' absent de facto control

Chennai ITAT sets aside TPO's order holding assessee (Indian company) and its overseas Distribution Partners (DPs) as "deemed AE" in terms of Sec. 92A(2)(i), deletes TP-adjustment of Rs. 2.51 Cr

Dec 01,2016

HC: Upholds ITAT’s remand of AMP transaction; RPM-applicability to be decided considering Sony HC-ruling

Delhi HC rules that ITAT’s observation to the effect that employing of Resale Price Method (‘RPM’) would virtually cast AMP outside the international transaction, cannot be held as conclusive; ITAT

Nov 29,2016

SC: Admits Revenue's SLP in Rampgreen case on KPO-BPO comparability; Expedites appeal hearing

SC admits Revenue's SLP in case of Rampgreeen Solutions P Ltd, directs that the appeal shall be heard within one year; Ruling in favour of assessee, Delhi HC had excluded 2

Nov 29,2016

HC: ITAT to itself adjudicate 15% RPT-filter issue for AY 2002-03, overrules remand to AO/TPO

Delhi HC modifies ITAT order for AY 2002-03 remanding the issue of exclusion of two comparables having related party transactions (RPT) to AO / TPO, rules that the matter shall

Nov 30,2016

ITAT: DRP-route inapplicable absent income-variation, tax-rate change irrelevant

Chennai ITAT upholds AO's action of directly issuing the assessment order u/s 143(3) without issuing a draft assessment order u/s 144C despite assessee being an ‘eligible assessee’ (i.e. a foreign company) u/s

Dec 02,2016

News

OECD clarifies CbCR implementation & transitional issues, investment funds / partnerships applicability

OECD releases additional guidance relating to implementation of Country-by-Country Reporting (CbCR) under BEPS Action 13, including key details of jurisdictions'

Dec 05,2016

KPMG Partner Karishma Phatarphekar quits, to lead BMR TP practice

KPMG Transfer Pricing (TP) Partner Karishma Phatarphekar quits, to lead BMR TP practice

Nov 16,2016

SLP in Maruti Suzuki AMP-case listed before SC on November 22

SLP in Maruti Suzuki AMP-case listed before SC on November 22

Nov 07,2016

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