Rulings

Feb 23,2017

Delhi HC refuses to admit Revenue’s appeal challenging ITAT’s deletion of TP-adjustment on account of Advertising, Marketing and Promotion (AMP) expenses in the case of Goodyear India for AYs 2007-08

Feb 22,2017

Delhi ITAT upholds CIT(A)'s approach of considering cost of raw-material obtained from AE as pass through cost, directs its exclusion from operating cost as well as operating revenue for computing

Feb 22,2017

Hyderabad ITAT questions TPO’s application of TNMM as against CUP adopted by cigarette manufacturer assessee for benchmarking transactions of purchase of tobacco leaves, processing charges and otherpayments made to AE;

View More

Feb 22,2017

ITAT quashes reopening of assessment u/s 147 on the basis of invalid TPO order, deletes TP-adjustment of Rs. 85.3 lakhs; Notes that when AO made a reference to TPO for

Feb 22,2017

ITAT remits TP-issues relating to selection of comparables for benchmarking software development services rendered by assessee to its AEs during AY 2008-09; Notes assessee’s grounds for inclusion / exclusion of

Feb 22,2017

ITAT deletes TP adjustment of Rs. 14.11 Cr on account of Advertising, Marketing and Promotion (AMP) expenses incurred by assessee for alleged promotion of the brand ‘Nippon’ in India, holds

View More

ITAT: Upholds TP-adjustment on outstanding AE-receivables considering ‘potential loss’ of income to assessee

Chennai ITAT dismisses assessee’s appeal challenging TP-adjustment towards notional interest on receivables outstanding from AE beyond 90 days; Rejects assessee’s arguments that it was a debt free company and profit

Feb 17,2017

ITAT: Deletes intangibles TP-adjustment; Higher weightage to Indian business justified considering business potential

Mumbai ITAT deletes TP-addition of Rs. 5.53 Cr on purchase of intangible assets (Trademarks, Customer lists and Goodwill) by assessee consequent to acquisition of credit card processing and merchant banking

Feb 21,2017

ITAT: Upholds profit-attribution on marketing activities of Indian-PE; ‘Force of attraction’ principle inapplicable

Delhi ITAT attributes 30% of profits to Indian branch (PE) of Singapore-based assessee (engaged in trading of medical equipment) in respect of direct sales in India by head office during

Feb 21,2017

ITAT: TPO's ALP-determination under TNMM lacks logic; Questions rejection of external quotes

Hyderabad ITAT questions TPO’s application of TNMM as against CUP adopted by cigarette manufacturer assessee for benchmarking transactions of purchase of tobacco leaves, processing charges and otherpayments made to AE;

Feb 22,2017

ITAT: Considers raw-material provided by AE as pass-through cost for computing GP margin

Delhi ITAT upholds CIT(A)'s approach of considering cost of raw-material obtained from AE as pass through cost, directs its exclusion from operating cost as well as operating revenue for computing

Feb 22,2017

News

Eye Share : Secondary adjustments – A paradigm shift towards arduous TP Regime

Nandakumar Raman (Director, Grant Thornton India LLP)    Balaji Ravindran (Assistant Manager)

Feb 23,2017

Apple challenges EC's interpretation of Irish law, raises 14 grounds in state-aid case

European Union publishes Apple’s appeal against European Commission (EC) ruling in the Apple-Ireland state aid case; EC had held that 2 tax

Feb 22,2017

Public CbCR to require qualified majority rather than unanimity : European Parliament

European Parliament’s Committee on Legal Affairs issues public opinion on legal basis of EC proposal relating to public Country-by-Country (CbC)

Feb 20,2017

View More

Top

Resource Center

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