Rulings

Aug 18,2017

Madras HC confirms ITAT order for AY 2009-10, holds that AO exceeded the jurisdiction by making new disallowance while passing order u/s 144C(13) giving effect to DRP directions when such

Aug 18,2017

Bangalore ITAT rules on selection of comparables for assessee providing software development services to AE for AY 2006-07; Rejects assessee’s plea to exclude ‘Aztec Software Systems’ & ‘Megasoft’ on the

Aug 17,2017

Delhi ITAT characterizes assessee’s operational outsourcing services to AE as low-end ITeS for AY 2012-13, refers to the definition of ITeS under the Safe Harbour Rules (‘SHR’) to establish that

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Aug 18,2017

Bangalore ITAT admits assessee’s additional ground seeking exclusion of 14 comparables on the grounds of functional dissimilarity and 4 other companies confirmed by DRP for assessee providing software development services

Aug 18,2017

Pune ITAT quashes draft assessment order passed by AO u/s 143(3) r.w.s. 144C(1) without following procedure laid down in Sec 144C for AY 2010-11; Notes that AO, on receipt of

Aug 18,2017

ITAT allows assessee’s miscellaneous application (relating to deductibility of license fee) for AY 2003-04 based on the contention that non-consideration of jurisdictional high court judgement would constitute a mistake apparent

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ITAT: Deletes penalty u/s 271BA considering assessee’s interpretation of Sec 92A provisions as ‘plausible view’

Mumbai ITAT deletes penalty levied by AO u/s 271BA for failure to furnish accountant’s report u/s 92E; Noting that levy of penalty u/s 271BA is subject to provisions of Sec

Aug 14,2017

ITAT: Characterizes operational outsourcing services as low-end ITeS; Refers to Safe Harbour Rules

Delhi ITAT characterizes assessee’s operational outsourcing services to AE as low-end ITeS for AY 2012-13, refers to the definition of ITeS under the Safe Harbour Rules (‘SHR’) to establish that

Aug 17,2017

ITAT: Upholds notional interest adjustment @ 10.25% on excess credit to AE

Bangalore ITAT dismisses assessee's appeal against notional interest adjustment on excess credit period allowed to AEs by assessee beyond 90 days for AYs 2003-04 & 2005-06; Rejects reliance placed by assessee on

Aug 16,2017

ITAT: Partially allows assessee’s miscellaneous petition; Recalls Tribunal-order for adjudicating working capital adjustment

Bangalore ITAT partially allows assessee’s miscellaneous petition seeking rectification of certain mistakes in Tribunal order dated April 28, 2017 for AY 2011-12; Noting that Tribunal had included ‘Infosys BPO Ltd’

Aug 14,2017

ITAT: Remits TP-adjustment on foreign bank's branch; CIT(A) not empower to remand matter

Delhi ITAT restores ALP-determination to TPO/AO in respect of assessee’s international transactions of marketing and support services for external commercial borrowings (ECB) issued by assessee's head office; Assessee is Indian

Aug 14,2017

News

UK updates CbCR Manual, restricts data usage to 'high level' TP risk assessment

UK HMRC updates ‘International Exchange of Information Manual’ [providing guidance on country-by-country (CbC) reporting format for multinationals] in light of

Aug 16,2017

US Tax Court holds cancellation of APAs by IRS as abuse of discretion

US tax Court holds that cancellation of APAs (entered with Eaton Corporation and Subsidiaries, ‘taxpayer’) by IRS was an abuse

Aug 04,2017

India notifies MCAA for automatic exchange of CbCR

India notifies Multilateral Competent Authority Agreement (MCAA) for automatic exchange of Country by Country Reports (CbCR); MCAA was signed by

Jul 31,2017

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