Rulings

Nov 01,2018

Delhi ITAT, in second round of proceedings, deletes notional interest adjustment on account of re-characterization of Redeemable Preference Shares (RPS) into loan & advances for AYs 2011-12 & 2012-13, rejects

Oct 29,2018

Kolkata ITAT holds that incurrence of AMP expenditure by assessee (performing value added distribution function akin to secondary manufacturing i.e. converting raw materials imported from AEs into pharmaceutical formulations) cannot

Oct 26,2018

Delhi ITAT deletes TP-adjustment towards depreciation on assets purchased from AE for leasing to independent parties in assessee's 'home base' segment for AY 2008-09; Notes that TPO had reallocated expenses

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Nov 16,2018

Delhi ITAT sets aside the issue of TPO-reference pursuant to Sec 263 proceedings, directs AO to pass fresh draft assessment order after referring the case to TPO and obtaining order

Nov 16,2018

Bangalore ITAT excludes Vishal Information Technologies and Accurate Data Converts Ltd citing failure to meet  25% employee cost filter; ITAT observes that "There is no gain saying that once a

Nov 16,2018

Delhi ITAT upholds TPO’s adoption of TNMM for benchmarking international transactions of assessee (engaged business of manufacturing of earth moving and construction equipment) for AY 2008-09, notes unchanged facts and circumstances vis-à-vis

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ITAT: Corporate guarantee, not ‘international transaction’, absent expenditure for extending the guarantee; Follows precedents

Visakhapatnam ITAT holds that corporate guarantee given by assessee to its 100% subsidiary to extend support/ assistance for business development would not constitute an international transaction u/s 92B for AY

Nov 14,2018

ITAT: Upholds aggregated benchmarking of import of spares/ completely built cars with manufacturing

Pune ITAT upholds assessee's stand of aggregating transactions of import of Completely Built Units (CBUs) and import of spare parts with transaction of manufacture of passenger cars for benchmarking, holds

Nov 12,2018

ITAT: Deletes TP-adjustment on expense reimbursement sans application of prescribed TP-method u/s 92C

Mumbai ITAT deletes TP-adjustment on reimbursement of expenses at cost from AE for AY 2008-09, holds that TP-method adopted by TPO for computing ALP was not as per any of

Nov 13,2018

ITAT: Upholds ITAT’s royalty adjustment deletion for assessee manufacturer; Follows earlier-order

Ahmedabad ITAT dismisses Revenue’s appeal challenging deletion of TP-adjustment on account of royalty payment to AE by assessee (engaged in the business of manufacturing and trading in air conditioners, washing

Nov 14,2018

ITAT: ALP determination mandatory u/s. 92, abnormal profits not reason to accept assessee's price

ITAT dismisses Revenue’s appeal for AY 2011-12, upholds assessee’s CPM and RPM as MAM over TPO’s TNMM for the international transactions of purchase of raw materials (manufacturing segment) and trading

Nov 14,2018

News

CBDT notifies new Form 36 / 36A for filing appeals / cross objections before ITAT

CBDT amends Form 36/36A for filing appeals / cross objections before ITAT; Amended Form 36 seeks detailed information about the

Oct 24,2018

OECD webcast highlights country approaches on digital economy, ​formulary apportionment not on agenda

The latest 'OECD Tax Talks' edition provides an update on the MLI, digitalized economy tax challenges, implementation of BEPS minimum

Oct 18,2018

Karnataka HC Special-Part X: Compilation of 6 rulings dismissing appeals on comparables following Softbrands

Compilation of rulings dismissing appeals on comparables following Softbrands ratioClick below to access details of 6 rulings of Karnataka HC.

Oct 12,2018

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