Rulings

Sep 22,2017

Delhi HC dismisses appeal filed by assessee (providing software development services/information technology services to its AEs) for AY 2009-10 owing to extraordinary appeal filing delay of 439 days; Notes that

Sep 21,2017

Delhi HC sets aside ITAT’s order remanding TP-issues in respect of international transactions undertaken in assessee’s (branch office of French Co) distribution, agency & marketing segments without giving any conclusive

Sep 21,2017

Delhi ITAT rules that assessee (engaged in providing wireless, high-speed internet access, Wi-Fi etc.) satisfied the need, benefit & rendition test in respect of 4 out of 7 categories of

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Sep 22,2017

Delhi ITAT restores TP-adjustment on account of receipt of intra-group services by assessee (engaged in providing network connectivity services) from AE for AY 2011-12; Notes that during the subject AY,

Sep 20,2017

Bangalore ITAT rejects TPO’s allocation of direct costs on turnover basis for assessee’s software development & ITeS segments for AY 2009-10; Notes that while assessee allocated direct costs on actual

Sep 19,2017

Bangalore ITAT dismisses second miscellaneous petition filed by Revenue against Tribunal order in case of Swiss Re Shared Services (India) for AY 2005-06; States that as per the amended provisions of Sec 254(2),

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ITAT: Rejects assessee’s attempt to cherry pick comparables year-on-year according to margin suitability

Delhi ITAT holds that assessee cannot be precluded from contesting exclusion of software product company merely because assessee had itself chosen comparables for its software R&D segment by adopting search

Sep 18,2017

ITAT: Forex expenditure irrelevant for comparable exclusion when incurred exclusively for relevant segment

Bangalore ITAT rules on selection of comparables on grounds of functional dissimilarity, availability of data, application of export earning filter etc. for assessee providing ITeS to AEs for AY 2010-11;

Sep 19,2017

ITAT: Rejects TPO’s CUP-method for intra-group services; Data availability ‘lifeline’ of method adopted

Delhi ITAT rules that assessee (engaged in providing wireless, high-speed internet access, Wi-Fi etc.) satisfied the need, benefit & rendition test in respect of 4 out of 7 categories of

Sep 21,2017

ITAT: AE’s transaction with European third-parties not CUP considering different market conditions

Delhi ITAT sets aside CIT(A)’s order accepting CUP method as MAM for benchmarking import of raw-materials by assessee (engaged in manufacturing auto components) from AE for AY 2007-08, upholds AO/TPO’s

Sep 20,2017

HC: Sets aside ITAT's remand; Selection of comparables unconnected with expense allocation issue

Delhi HC sets aside ITAT’s order remanding TP-issues in respect of international transactions undertaken in assessee’s (branch office of French Co) distribution, agency & marketing segments without giving any conclusive

Sep 21,2017

News

OECD updates IT-tools for information exchange under CRS, on CbCR & tax rulings

OECD releases updated and new IT-tools and guidance supporting technical implementation of tax information exchange under the Common Reporting Standard (CRS), on

Sep 20,2017

Unilateral measures addressing digital economy challenges benefit developing countries most: UN-Committee note

UN Committee of Experts on International Cooperation in Tax Matters releases note on selected issues under digital economy which are

Sep 11,2017

Key takeaways of OECD's guidance on implementation and appropriate use of CbCR

OECD's revised guidance on implementation of Country by Country Report (CbCR) covers 3 aspects - a) definition of revenues, b) treatment of

Sep 06,2017

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