Rulings

Jan 18,2019

Delhi ITAT deletes AMP-adjustment for assessee [engaged in manufacturing, trading and marketing of electronics and home-appliances] for AY 2008-09; Opining that incurring of AMP-expenditure does not give rise to any

Jan 17,2019

Mumbai ITAT accepts assessee’s plea for exclusion of TCS E-Serve as comparable for assessee providing ITeS to AE for AY 2012-13; Notes that turnover of TCS E-Serve (Rs.1578.44cr) was 23

Jan 16,2019

Bombay HC upholds ITAT-order rejecting AO’s appeal against DRP's revised order for pre-2012 objections for AY 2007-08, rejects Revenue's reliance on Sec 253(2A); Observes that assessee’s objections (filed on 23.12.2010)

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Jan 18,2019

Delhi ITAT, in second round of appeal pursuant to HC remand, deletes AMP-adjustment for assessee (a sole distributor of Sony products in India) for AY 2008-09; Follows co-ordinate bench ruling

Jan 18,2019

Chennai ITAT remits issue of selection of comparable to the file of AO/TPO for fresh consideration for assessee (engaged in manufacture and export of ornamental trimmings, tassels and tie-backs) for

Jan 18,2019

Mumbai ITAT includes Cyber Media Research Ltd and ICRA online Ltd as comparables for assessee (engaged in providing engineering and polyolefins products related services, technical support and other consultancy services

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ITAT: Deletes AMP-adjustment; Popularity of global brand not only due to Sony-India’s efforts

Delhi ITAT, in the second round of litigation pursuant to HC remand, deletes AMP-adjustment for assessee (a sole distributor of Sony products in India) for AY 2007-08, holds that “by

Jan 15,2019

HC: Routing money through AE for distribution rights acquisition from third-party, not ‘international-transaction’

Bombay HC upholds ITAT order for AY 2009-10, holds that the transaction of routing money through AE by assessee (engaged in production and distribution of films) for specific purpose of

Jan 15,2019

HC: Allows writ; ITAT erred in remitting ALP-determination, without characterizing distribution fees

Bombay HC allows assessee’s writ, sets aside ITAT-order rejecting assessee’s rectification applicant against Tribunal order restoring ALP-determination of distribution fees paid to AEs without deciding on characterization of the said

Jan 14,2019

ITAT: Timex-India’s AMP-expenses not for AE-brand promotion, considers 87% turnover from India-sales

Delhi ITAT rules on AMP adjustment and selection of comparables for assessee engaged in manufacturing and sale of watches and distribution of watches imported from its AE and ITeS for

Jan 14,2019

ITAT: Event management not comparable to Marketing Support Services; Excludes Asian Business Exhibition

Bangalore ITAT rules on comparable selection for assessee providing marketing support services to its AEs for AY 2011-12; Excludes Asian Business Exhibition & Conferences Ltd as a comparable accepting assessee’s

Jan 14,2019

News

CBDT prescribes March 31, 2019 deadline for entities in jurisdictions not having CbCR-exchange agreement

CBDT, as a one-time measure, extends period of furnishing CbCR by constituent entities referred to u/s 286(4)(a)/(aa) in respect of

Dec 26,2018

CBDT: Relaxes CbCR furnishing deadline for entities from countries having systemic failure

CBDT prescribes 12 month time period under Rule 10DB(4) for furnishing CbCR by constituent entity of an international group resident

Dec 19,2018

Australia releases draft practical compliance guideline addressing TP-issues for inbound distribution arrangements

Australian Taxation Office (‘ATO’) releases draft practical compliance guideline addressing transfer pricing (TP) issues related to inbound distribution arrangements; The

Nov 30,2018

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