Rulings

Sep 30,2016

Delhi ITAT sets aside CIT(A) order deleting TP-adjustment in respect of `Software development and customized electronic data’ services provided by assessee to its AE during AY 2005-06, remits comparability of Datamatics Ltd

Sep 30,2016

Delhi HC dismisses Revenue’s appeal, upholds ITAT’s inclusion of Himachal Futuristic Communication Ltd (HFCL) as a comparable for benchmarking receipt of technical service from AE for AY 2005-06; ITAT had

Sep 30,2016

Delhi ITAT admits fresh evidence filed by assessee, agrees that TPO’s characterization of assessee (a 100% subsidiary of ControlRisks Group Holding Ltd., London) as engaged in providing “Investment and other financial advisory”

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Sep 29,2016

ITAT rules on selection of comparables for assessee providing software development and support services to AE for AY 2010-11; Excludes 3 comparables on grounds of functional dissimilarity and remits comparability

Sep 29,2016

ITAT sets aside CIT(A)’s order applying 0% RPT filter without examining functional comparability of companies while benchmarking assessee’s international transaction for AY 2005-06; Considers Revenue’s submission that accepted level of

Sep 29,2016

ITAT deletes TP addition for AY 2009-10 in respect of transactions between Indian head office and branch office in Canada because of aggregation of financial results; Follows decision for earlier

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ITAT: Reimbursement to AE mere pass-through cost; Deletes TP-adjustment absent rendering of service

Delhi ITAT upholds CIT(A)’s deletion of TP-adjustment made by TPO by adding a mark-up on reimbursement of cost by AE to assessee in wireless segment for purchase and supply of

Sep 26,2016

HC: Absence of segmental accounts does not warrant entity-wise adjustment, dismisses Revenue's appeal

Bombay HC dismisses Revenue's appeal, rejects Revenue's argument that TP-adjustment has to be made at entity level where segmental accounts are not maintained by assessee regularly; Rejects Revenue's reliance on cases

Sep 27,2016

HC: Quashes Tribunal order directing use of international database for ALP-determination

Bombay HC quashes Tribunal order directing ITAT to decide appeals filed by assessee (a company engaged in the manufacture of fible glass pressure vessels used for water treatment) and Revenue afresh

Sep 29,2016

ITAT: Deletes TP-adjustment on business transfer to foreign-AE's Indian-branch; Rule 10AB inapplicable to AY 2010-11

Chennai ITAT holds that consideration on transfer of software undertaking by assessee-company (a captive software developer) to Indian branch of its AE (ultimate holding company in Italy) is taxable as

Sep 27,2016

ITAT: Refuses stay; Can't select comparables merely relying on precedents without FAR analysis

Delhi ITAT dismisses assessee’s stay of demand application for AY 2011-12, upholds AO’s order granting stay of Rs 8.50cr demand subject to payment of 15% demand in 2 installments; Notes

Sep 26,2016

News

Akhilesh Ranjan bats for marketing intangibles disclosures in CbC local file reporting

Akhilesh Ranjan (Principal CCIT - International tax and Transfer Pricing) speaks about tax policy and Country by Country Reporting (CbCR) at IFA’s

Sep 30,2016

Aggregation of transactions – Analysing judicial precedents

Rohit Gupta (FCA, LLB, Director, B.K.Khare & Co., Author of 'Principles of International Tax Planning')

Sep 09,2016

No longer the “Apple” of Ireland’s Eye – Tracing the Apple Tax Controversy history in 10 steps

No longer the “Apple” of Ireland’s Eye – Tracing the Apple Tax Controversy history in 10 steps.

Sep 01,2016

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