Rulings

Dec 07,2018

Mumbai ITAT rejects assessee’s (engaged in the business of outdoor media advertising services) Nil ALP-determination of loans granted to AEs on the basis that their recovery was doubtful owing to

Dec 06,2018

Delhi ITAT rules on selection of comparables, MAM, PLI and grant of capacity adjustment in manufacturing segment of assessee (engaged in manufacturing products to be assembled in the manufacturing of

Dec 04,2018

Delhi ITAT deletes AMP-adjustment for Pepsi Co India (full-fledged manufacturer) for AYs 2006-07 to 2013-14, holds that firstly, there is no international transaction in the form of any agreement/ arrangement

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Dec 06,2018

Pune ITAT grants stay of outstanding tax demand of Rs.1.19cr (which arose due to TP-adjustment) for a period of 180 days from order date or till appeal disposal, whichever is

Dec 06,2018

 Chennai ITAT rules on selection of comparables in assessee’s Engineering Design Services (EDS) segment, ITeS & Assembly activities for AY 2013-14; Excludes Acropetal under EDS Segment citing abnormal margins, Infosys

Dec 05,2018

Delhi ITAT rules on selection of comparables for assessee engaged in providing business development, advisory and other support services to its AEs for AY 2010-11; In response to assessee’s contention

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ITAT: Deletes Rs.2800cr+ AMP-adjustment for PepsiCo, a full-fledged manufacturer; Rejects PSM/BLT for benchmarking

Delhi ITAT deletes AMP-adjustment for Pepsi Co India (full-fledged manufacturer) for AYs 2006-07 to 2013-14, holds that firstly, there is no international transaction in the form of any agreement/ arrangement

Dec 04,2018

SC: Dismisses Revenue’s SLP against HC-order upholding 25% RPT-filter application & Wipro exclusion

SC dismisses Revenue’s SLP against HC order upholding application of 25% RPT filter & exclusion of Wipro Ltd for comparability analysis for AY 2007-08; HC had opined that RPT filter is relevant and

Dec 04,2018

ITAT: TPO cannot arbitrarily interfere with PLI-selection; Sec 41(1)-waiver irrelevant for intra-group services benchmarking

Delhi ITAT rules on selection of comparables, MAM, PLI and grant of capacity adjustment in manufacturing segment of assessee (engaged in manufacturing products to be assembled in the manufacturing of

Dec 06,2018

ITAT: Rejects assessee's Nil interest-ALP for stressed AE-loans citing commercial expediency, revenue neutrality

Mumbai ITAT rejects assessee’s (engaged in the business of outdoor media advertising services) Nil ALP-determination of loans granted to AEs on the basis that their recovery was doubtful owing to

Dec 07,2018

ITAT: Allows additional evidence admission to decide PwC’s entity vs. transaction level adjustment issue

Kolkata ITAT allows PwC’s application for admission of additional evidence (under Rule 29 of ITAT Rules) in form of segmental profits regarding TP-adjustment on provision of management consultancy services to

Dec 03,2018

News

Australia releases draft practical compliance guideline addressing TP-issues for inbound distribution arrangements

Australian Taxation Office (‘ATO’) releases draft practical compliance guideline addressing transfer pricing (TP) issues related to inbound distribution arrangements; The

Nov 30,2018

EU Joint TP Forum outlines 10 key recommendations on coordinated approach to TP-controls

EU Joint TP Forum releases a Report on coordinated approach to TP-controls within EU; Report, consisting of 10 key recommendations,

Nov 29,2018

CBDT outlines recommended approaches to deal with rulings exchanged under BEPS Action 5

CBDT’s FT&TR division releases guidance on 5 types of rulings received from other jurisdictions under BEPS Action 5; The guidance

Nov 28,2018

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