Rulings

Mar 21,2017

Delhi ITAT sets aside CIT(A) order deleting TP addition in respect of assessee’s international transaction pertaining to `Purchase of material’ for AY 2005-06, holds that “all the points taken note of

Mar 21,2017

Bangalore ITAT holds that assessee’s remittance to subsidiary for subscription of equity shares constitutes international transaction u/s 92B considering extraordinary delay in allotment of shares, holds that the transaction has

Mar 20,2017

Chandigarh ITAT upholds assessee’s selection of foreign AE as tested party for benchmarking international transaction of provision of IT/IT enabled services for AY 2010-11, rejects Revenue’s contention that reliable data

View More

Mar 24,2017

ITAT dismisses miscellaneous petition filed by assessee seeking rectification of mistake in ITAT order for AY 2011-12; ITAT had set aside comparability of one company viz. Jeevan Scientific Technology Ltd.

Mar 24,2017

ITAT adjudicates on stay petitions filed by assessee for AYs 2009-10 and 2010-11 for outstanding demand of Rs. 5.97 crores and 1.74 crores respectively; For AY 2009-10, ITAT notes that

Mar 24,2017

ITAT allows assessee’s appeal to exclude 5 comparables for benchmarking ITES services for AY 2008-09; Excludes ‘Coral Hub Limited’ having low employee cost (as major portion of its work was

View More

ITAT: Accepts foreign-AE a tested party; Rejects Revenue’s claim regarding non-availability of comparable data

Chandigarh ITAT upholds assessee’s selection of foreign AE as tested party for benchmarking international transaction of provision of IT/IT enabled services for AY 2010-11, rejects Revenue’s contention that reliable data

Mar 20,2017

ITAT: Upholds re-characterization of share-application as debt considering allotment delay / AE fund availability

Bangalore ITAT holds that assessee’s remittance to subsidiary for subscription of equity shares constitutes international transaction u/s 92B considering extraordinary delay in allotment of shares, holds that the transaction has

Mar 21,2017

ITAT: Vetoes CIT(A) order deleting TP-addition, ‘tax avoidance intent’ extraneous to ALP-determination

Delhi ITAT sets aside CIT(A) order deleting TP addition in respect of assessee’s international transaction pertaining to `Purchase of material’ for AY 2005-06, holds that “all the points taken note of

Mar 21,2017

HC: Admits Revenue’s appeal challenging ITAT-order deleting TP-adjustment on technical fees payment

Gujarat HC admits Revenue’s appeal challenging ITAT’s deletion of Rs. 1.48 Cr TP addition on account of payment of technical services made by assessee (rubber parts manufacturer) to its AE;

Mar 20,2017

HC: Upholds ITAT order deleting AMP adjustment following HC order for earlier year

Upholds ITAT order deleting adjustment on AMP expenses for AY 2010-11; Notes that ITAT followed its own orders for previous years as well as HC order in assessee’s own case for

Mar 23,2017

News

US Tax Court rules in Amazon's favour over TP-dispute on intangibles transfer to Luxembourg subsidiary

US Tax Court rules in favor of Amazon US in respect of transfer pricing adjustments amounting to $8.3mn and $225mn

Mar 24,2017

CBDT clarifies rollback availability for bilateral APA under revised India-Korea DTAA

CBDT clarifies that rollback provision is available in respect of bilateral Advance Pricing Agreement (APA) applications filed by taxpayers under

Mar 17,2017

View More

Top

Resource Center

Gain access to insightful resources, carrying useful observations on relevant issues!