Rulings

Apr 26,2017

Madras HC dismisses writ petition filed by assessee challenging order passed by AO giving effect to ITAT directions for AYs 2010-11 and 2011-12, holds that alternative remedy was available to

Apr 26,2017

Chennai ITAT declines idle capacity adjustment for AY 2006-07 in case of assessee engaged in manufacturing & export of tractors, holds that the assessee company had failed to justify the

Apr 26,2017

Bangalore ITAT upholds TP-adjustment on royalty payment stating that assessee failed to discharge its onus of establishing the justification for clubbing and aggregating royalty transaction with other transactions; Rejects assessee’s contention

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Apr 26,2017

Bangalore ITAT excludes 4 functionally dissimilar comparables for assessee providing  accounting and transaction processing work in the nature of ITES to AE for AY 2009-10, relies on e4e Business Solutions

Apr 26,2017

ITAT remits TP-issue of selection of foreign AE as tested party and admits additional evidence in respect of reimbursement of expenses to AE for assessee (engaged in ITeS) for AY

Apr 25,2017

Chennai ITAT provides assessee an opportunity to substantiate its claim of expenditure in the nature of management fees paid to its AEs during AY 2012-13, remits issue to DRP; Notes

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ITAT: Rejects internal-TNMM considering technological / brand differences; Disapproves restricting TP-adjustments to AE-transactions

Chennai ITAT rejects use of internal TNMM adopted by Caterpillar India (assessee) for benchmarking manufacturing of heavy earthmoving machinery, holds that non-CAT segment (comprising of products of erstwhile Hindustan Motors) cannot

Apr 21,2017

ITAT: Wipro-Tech fails RPT-filter as its entire turnover constitutes deemed international transaction

Delhi ITAT excludes 4 comparables for assessee providing captive software development services to AE for AY 2010-11; Excludes Wipro Technology Services Ltd (acquired from Citi Group) as it failed 25%

Apr 21,2017

SC: Admits Revenue’s SLP in Toshiba’s case on AMP-issue, tags appeal with Sony Ericsson

SC admits SLP filed by Revenue against Delhi HC judgment in the case of Toshiba India (P) Ltd. on marketing intangibles issue, tags it with the case of Sony Ericsson Mobile Communications

Apr 24,2017

ITAT: Confirms TP-adjustment on royalty payment, assessee failed to justify aggregation of transactions

Bangalore ITAT upholds TP-adjustment on royalty payment stating that assessee failed to discharge its onus of establishing the justification for clubbing and aggregating royalty transaction with other transactions; Rejects assessee’s contention

Apr 26,2017

ITAT: Upholds denial of capacity adjustment absent empirical data showing billable man-hours working

Chennai ITAT upholds TPO’s rejection of idle capacity adjustment for AY 2009-10 observing that assessee was unable to place data showing total billable hours which could be objectively analyzed; Noting

Apr 25,2017

News

Eye Share: Australian Full Federal Court's Chevron ruling - An analysis

Ayush J. Rajani (Managing Partner, AKR Advisors LLP)

Apr 25,2017

‘Operation clean money’ & ‘Demonetisation’ part of CBDT’s current quarter action plan

CBDT releases interim action plan for first quarter of FY 2017-2018; Sets May 31st deadline for verification of data of

Apr 18,2017

UN releases updated TP-Manual containing new chapters on intra-group services, CCAs & intangibles

UN releases revised Transfer Pricing Manual for Developing Countries (2017 edition) in digital format at the ECOSOC Special Meeting on 7

Apr 12,2017

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