Rulings

Jan 16,2017

Mumbai ITAT upholds CIT(A) order for AY 2006-07 deleting TP addition on buy-back of equity shares of its wholly owned subsidiary in US by re-characterizing the investment transaction as loan;

Jan 12,2017

Chennai ITAT upholds TNMM adopted by assessee over CUP method for benchmarking payment to AE towards Research and Development (R&D) and management fees for AYs 2009-10, 2010-11 and 2011-12; TPO

Jan 12,2017

Bombay HC dismisses Revenue's appeal against ITAT order directing inclusion of two loss making comparables and considering DEPB (Duty Entitlement Passbook) benefits and depreciation while computing assessee’s margin for AY

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Jan 16,2017

ITAT upholds CIT(A)’s exclusion of ‘M/s. Mould Tech Technologies Ltd.’ from the list of comparables for benchmarking IT Enabled services (ITeS) rendered by assessee to its AEs during AY 2007-08;

Jan 13,2017

ITAT upholds exclusion of ‘Onward Technologies Ltd.’ as comparable for benchmarking Design Engineering and IT Enabled services (ITeS), on the ground that it was a consistent loss making company for

Jan 13,2017

ITAT rules on selection of comparables in case of assessee providing non-binding investment advisory services to its AE for AY 2011-12; Upholds DRP’s exclusion of ‘Motilal Oswal Investment Advisory’ and

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ITAT: Quashes reassessment absent fresh, tangible material; Confirms DRP’s power to annul assessment

Pune ITAT rules that reassessment proceedings initiated by AO u/s 147 for AY 2005-06 on the basis of Form 3CEB furnished by group company of assessee, were without jurisdiction and unsustainable,

Jan 10,2017

HC: Rule 10B(2) parameters ‘exhaustive’; Excluding loss-making comparables without examining comparability unjustified

Bombay HC dismisses Revenue's appeal against ITAT order directing inclusion of two loss making comparables and considering DEPB (Duty Entitlement Passbook) benefits and depreciation while computing assessee’s margin for AY

Jan 12,2017

ITAT: Upholds entity-level TNMM for R&D & management fee absent reliable comparable under CUP

Chennai ITAT upholds TNMM adopted by assessee over CUP method for benchmarking payment to AE towards Research and Development (R&D) and management fees for AYs 2009-10, 2010-11 and 2011-12; TPO

Jan 12,2017

ITAT: Adopts arm’s length interest rate of LIBOR+2% or 7%, whichever is higher

ITAT directs TPO to adopt arm’s length interest rate of LIBOR +2% or 7%, whichever is higher, for benchmarking interest received by assessee on loans advanced to subsidiaries during AYs

Jan 10,2017

ITAT: DRP empowered to make disallowance under different provisions despite TP-adjustment deletion

ITAT remits issue relating to disallowance made by DRP for AY 2011-12 on account of interest payable on Compulsorily Convertible Debentures (CCDs) issued by assessee in FY 2007-08; Notes that

Jan 10,2017

News

CBDT's year-end review highlights CbCR implementation and achievements in APA/MAP resolutions

CBDT publishes Year End Review – 2016 showcasing major achievements during current financial year 2016-17 so far; On the transfer

Jan 10,2017

CBDT: India-Kazakhstan sign protocol to insert LoB clause, allow MAP-access in TP-cases

CBDT: India-Kazakhstan sign protocol to insert LoB clause, allow MAP-access in TP-cases

Jan 06,2017

KPMG Partner and ex-IRS officer Ajit Jain quits

KPMG Partner and ex-IRS officer Ajit Jain quits

Jan 05,2017

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