Rulings

Feb 20,2018

Delhi ITAT, in second round of proceedings, dismisses assessee’s appeal against AO’s final assessment order (passed without a draft assessment order) as non-maintainable for AY 2012-13, holds that appropriate remedy

Feb 20,2018

Delhi ITAT upholds TPO’s aggregation of ITES and software development services (SDS) for benchmarking under TNMM absent assessee’s substantiation for bifurcation of the segments for AY 2013-14; Observes that assessee

Feb 17,2018

Chennai ITAT deletes TP-adjustment of Rs. 178 Cr in case of Renault India (assessee) for AY 2012-13, holds that transaction of purchase of cars from a resident entity RNAIPL (related

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Feb 22,2018

Delhi ITAT restores issue of levy of concealment penalty u/s 271(1)(c) back to file of AO in case of NDTV for AY 2007-08; Notes that Tribunal, in quantum appeal, vide order dated

Feb 22,2018

Bangalore ITAT grants extension of stay of demand to Manipal Global Education Services up to March 31, 2018 for AY 2010-11; Notes that “existence of all conditions for grant of stay has already been considered by the Tribunal

Feb 22,2018

Delhi ITAT rules on selection of comparables for assessee providing coordination, liasioning, administrative support and other ITeS to AE for AY 2008-09; Accepts assessee’s contention for exclusion of e-Clerx Services

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ITAT: Renault India's transaction with Renault Nissan India, not international transaction; Deletes Rs. 178 cr adjustment

Chennai ITAT deletes TP-adjustment of Rs. 178 Cr in case of Renault India (assessee) for AY 2012-13, holds that transaction of purchase of cars from a resident entity RNAIPL (related

Feb 17,2018

ITAT: Dismisses appeal against final assessment post-remand as non-maintainable, guides assessee to CIT(A)/HC

Delhi ITAT, in second round of proceedings, dismisses assessee’s appeal against AO’s final assessment order (passed without a draft assessment order) as non-maintainable for AY 2012-13, holds that appropriate remedy

Feb 20,2018

ITAT: Upholds TPO’s aggregation of ITES, software segments; Deviates from earlier years' approach

Delhi ITAT upholds TPO’s aggregation of ITES and software development services (SDS) for benchmarking under TNMM absent assessee’s substantiation for bifurcation of the segments for AY 2013-14; Observes that assessee

Feb 20,2018

ITAT: Decides appeal ex-parte absent representation by assessee; Confirms CIT(A)’s-order on TP-issues

Bangalore ITAT dismisses assessee’s appeal challenging TP-adjustments in respect of corporate guarantee, loan, outstanding receivables etc. for AYs 2011-12 & 2013-14; Noting that none appeared on behalf of assessee despite

Feb 19,2018

ITAT: Follows Cerner-Heathcare ruling on comparables selection for software-developer as assessee’s profile similar

Bangalore ITAT rules on comparables selection in respect of assesse providing software development services to AE for AY 2010-11; Notes that profile of Cerner Healthcare Solutions (ruling relied upon  by assessee)

Feb 16,2018

News

UK 's MAP-policy paper expresses willingness to consider interest deduction pursuant to secondary adjustment

UK HMRC releases Statement of Practice (‘SoP’) on Mutual Agreement Procedure (‘MAP’) to set out UK’s practice regarding methods to reduce/prevent

Feb 21,2018

KPMG Transfer Pricing Head Rahul Mitra resigns, likely to join Dhruva Advisors

KPMG India Transfer Pricing Head Rahul Mitra resigns, likely to join Dhruva Advisors : Sources

Feb 12,2018

Business Connection's digital nexus - A global comparative analysis

Over the last couple of years, the Government has enacted several provisions in line with OECD’s Base Erosion and Profit

Feb 05,2018

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