Rulings

Jun 22,2017

Delhi ITAT upholds interest adjustment on delayed AE-receivables for assessee (engaged in executing engineering design and drawing for AEs) for AY 2012-13; Distinguishes assessee’s reliance on co-ordinate bench ruling in assessee’s

Jun 21,2017

Bangalore ITAT remits computation of total cost for ALP-determination of software development services for fresh decision for AY 2003-04; Notes that AE provided certain fixed assets on free of cost

Jun 20,2017

Madras HC dismisses assessee’s writ petition challenging DRP-order (refusing to condone assessee’s delay in filing objections before it) and consequent final assessment order by AO making the TP-adjustment for AY

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Jun 23,2017

Bangalore ITAT partly allows assessee’s miscellaneous petition, modifies ITAT order pertaining to AY 2006-07 to exclude Mega Soft Ltd as a comparable in place of Lanco Global Solutions Ltd applying

Jun 21,2017

Delhi ITAT remits TP-adjustment in respect of AMP-expenses related to selling and distribution activities for MSD Pharmaceuticals for AY 2011-12; Follows co-ordinate bench ruling in assessee’s own case in earlier

Jun 21,2017

Delhi ITAT quashes assessment framed in the name of non-existent amalgamating company for AY 2006-07; Notes that pursuant to Karnataka HC order for merger (dated January 9, 2009), assessee stood

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ITAT: Excludes ESOPs but includes unaccounted support services in operating-cost for software services

Bangalore ITAT remits computation of total cost for ALP-determination of software development services for fresh decision for AY 2003-04; Notes that AE provided certain fixed assets on free of cost

Jun 21,2017

HC: Upholds LIBOR on interest-free advances to wholly owned subsidiaries, applies Tata Autocomp ratio

Bombay HC confirms ITAT order directing use of LIBOR + 2% as arm's length interest rate in respect of interest free advances given by assessee to its wholly owned subsidiaries

Jun 19,2017

ITAT: Upholds interest adjustment on delayed AE-receivables; Distinguishes earlier order in own case

Delhi ITAT upholds interest adjustment on delayed AE-receivables for assessee (engaged in executing engineering design and drawing for AEs) for AY 2012-13; Distinguishes assessee’s reliance on co-ordinate bench ruling in assessee’s

Jun 22,2017

HC: Construes objections dismissed on ground of delay as DRP-direction; Dismisses assessee’s writ

Madras HC dismisses assessee’s writ petition challenging DRP-order (refusing to condone assessee’s delay in filing objections before it) and consequent final assessment order by AO making the TP-adjustment for AY

Jun 20,2017

ITAT: Excludes TCS E-serve and Wipro for benchmarking software development services; Follows precedents

Mumbai ITAT rules on selection of comparables for assessee rendering software development and localization services to AE for AY 2011-12; Excludes TCS E-Serve Ltd as it was functionally dissimilar, benefitted

Jun 19,2017

News

OECD releases updated guidance on developing countries' difficulties in accessing comparables

Platform for Collaboration on Tax (a joint initiative of the IMF, OECD, UN and World Bank Group) publishes updated toolkit (following

Jun 23,2017

OECD appoints Tomas Balco as Head of Transfer Pricing Unit

OECD appoints Mr. Tomas Balco as Head of the Transfer Pricing Unit in the Centre for Tax Policy and Administration

Jun 23,2017

OECD releases BEPS discussion drafts on PE profits attribution & transactional profit splits

OECD releases new/revised BEPS discussion drafts on PE profits attribution, transactional profit splits; Revises drafts issued in July 2016.

Jun 22,2017

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