Rulings

May 21,2018

Mumbai ITAT rejects TPO’s entity wide approach for benchmarking international transactions in respect of International Express and International Freight Forwarding segments of assessee [engaged in the business of transportation to

May 18,2018

Pune ITAT sets aside DRP order rejecting admission of additional evidences filed by assessee to support its contention that its foreign AE can be selected as tested party for benchmarking

May 17,2018

Delhi ITAT holds that any claim to treat expenditure as extra-ordinary and not arising in normal course of business "needs to be demonstrated with strict evidence”; Upholds CIT(A)’s allowance of adjustment of expenses

View More

May 22,2018

Pune ITAT dismisses Revenue’s appeal, upholds CIT(A)’s order restricting TP-adjustment only to assessee’s international transactions for AY 2009-10; Notes that while TPO computed assessee’s PLI on the entire sales of

May 22,2018

Mumbai ITAT rejects application for stay of demand by assessee [engaged in business of manufacturing of all types of organic chemicals, aromatic ingredients, etc.] for AY 2013-14; Notes that demand

May 22,2018

Pune ITAT admits additional evidence filed by assessee [engaged in the business of interior design, development, manufacturing and assembly of automotive seating system and engineering services to automotive industry] in

View More

ITAT: DRP proceedings a continuation of assessment, additional evidence consideration a must

Pune ITAT sets aside DRP order rejecting admission of additional evidences filed by assessee to support its contention that its foreign AE can be selected as tested party for benchmarking

May 18,2018

ITAT: Grants partial adjustment for extra-ordinary costs, emphasizes need to demonstrate with evidence

Delhi ITAT holds that any claim to treat expenditure as extra-ordinary and not arising in normal course of business "needs to be demonstrated with strict evidence”; Upholds CIT(A)’s allowance of adjustment of expenses

May 17,2018

ITAT: Management costs satisfy 'benefit test' but directs CUP over TNMM for benchmarking

Delhi ITAT remits ALP determination of payment of management group cost back to AO/TPO for deciding afresh by applying the CUP method for AYs 2008-09, 2009-10 & 2012-13; Notes that

May 16,2018

ITAT: Rejects entity level benchmarking, assessee’s domestic segment not extension of international business

Mumbai ITAT rejects TPO’s entity wide approach for benchmarking international transactions in respect of International Express and International Freight Forwarding segments of assessee [engaged in the business of transportation to

May 21,2018

ITAT: Deletes adjustment; TPO's ALP-determination of royalty, technical fee payment & commission income, unsustainable

Delhi ITAT deletes TP-adjustment on royalty and technical service fee made by determining ALP at Nil for AY 2013-14, holds that TPO/DRP cannot put themselves in the shoes of assessee

May 16,2018

News

UN Model Convention 2017 introduces anti-abuse rules, new FTS article; Incorporates BEPS language

United Nation releases 2017 update of the Model Double Taxation Convention between Developed and Developing Countries;  The UN Model Convention

May 18,2018

OECD considers revising TP-guidelines on dispute resolution & intra-group services, seeks comments

OECD considers two new projects i.e. revising the guidance in Chapter IV (administrative approaches) and Chapter VII (intra-group services) of

May 09,2018

US 2017 APA Report: IRS signs 116 APAs in 2017; India accounts for 21% of total bilateral APA filings in 2017

US IRS issues 19th Annual Advance Pricing Agreement (APA) Report for calendar year 2017, highlights signing of 116 APAs (30 unilateral,

Apr 23,2018

View More

Top

Resource Center

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