Rulings

Jan 17,2018

Karnataka HC dismisses Revenue’s writ with 'exemplary' cost of Rs. 50,000 each, to be paid personally by 2 Principal CITs & an ACIT, for their irresponsible & unfair behaviour in

Jan 16,2018

Kolkata ITAT deletes TP-adjustment in respect of corporate guarantee provided  to 100% Mauritius subsidiary for AY 2011-12 accepting assessee’s contention that corporate guarantee was provided as a matter of commercial

Jan 16,2018

Mumbai ITAT rules that writing off of obsolete stock worth Rs. 6.48 crore by assessee for AY 2010-11 was an extraordinary event and not an international reimbursement transaction whose fair

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Jan 21,2018

Bangalore ITAT dismisses assessee’s Miscellaneous Petition (MP) alleging certain apparent mistakes in the impugned Tribunal order for AY 2011-12; Notes assessee’s contention that ITAT proceeded on wrong basis that there

Jan 21,2018

Bangalore ITAT excludes 15 out of 26 comparables selected by TPO on various grounds such as/functional dissimilarity, ownership of intangibles, absence of segmental details, outsourcing of work etc. for software

Jan 21,2018

Bangalore ITAT remits comparability of Bodhtree Consulting Ltd back to the DRP for AY 2009-10; Considers assessee’s submission that DRP’s order was very cryptic as he included Bodhtree Consulting by

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ITAT: Corporate guarantee provided without cost, outside ‘international transaction’ ambit; Deletes TP-adjustment

Kolkata ITAT deletes TP-adjustment in respect of corporate guarantee provided  to 100% Mauritius subsidiary for AY 2011-12 accepting assessee’s contention that corporate guarantee was provided as a matter of commercial

Jan 16,2018

ITAT: Rejects 'benefit test' under garb of 'CUP' for intra-group services ALP-determination

Pune ITAT deletes TP-adjustment on payment of fees for advisory and other services rendered by AE for AY 2009-10 & 2010-11, holds that analysis done by TPO as to nature

Jan 15,2018

HC: Revenue Officers get tongue-lashing for 'unholy' desire to multiply litigations; Exemplary costs imposed

Karnataka HC dismisses Revenue’s writ with 'exemplary' cost of Rs. 50,000 each, to be paid personally by 2 Principal CITs & an ACIT, for their irresponsible & unfair behaviour in

Jan 17,2018

ITAT: Obsolete stock write-off an extraordinary event, not international transaction; Deletes TP-adjustment

Mumbai ITAT rules that writing off of obsolete stock worth Rs. 6.48 crore by assessee for AY 2010-11 was an extraordinary event and not an international reimbursement transaction whose fair

Jan 16,2018

HC: Upholds forex-fluctuation treatment as operating item, follows Cashedge; Admits legal question on comparables

HC upholds ITAT’s consideration of forex gain/ losses as operating for assessee & comparables while determining ALP for AY 2010-11; While arriving at its decision, ITAT had also rejected applicability

Jan 16,2018

News

1400+ bilateral relationships established for CBCR automatic exchanges including India's 50+ activated relationships

OECD takes further step to implement Country-by-Country (CbC) Reporting in accordance with the BEPS Action 13 minimum standard, through activation of

Dec 22,2017

OECD tax talks highlight digital economy, MAP peer-reviews & forthcoming G20 agenda

OECD tax talks eight session provides an update on revenue statistics, tax challenges of the digitalized economy, MLI matching results,

Dec 19,2017

Key takeaways from Taxsutra's 3 city CbCR event

Year 2017 is the first year when the Indian taxpayers are required to do compliances regarding Master File (MF) and

Dec 04,2017

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