Rulings

Aug 25,2016

Ahmedabad ITAT, in second round of proceedings, rejects Revenue's contention for constitution of Special Bench ('SB') for deciding issue regarding selection of a non-resident entity as a tested party in

Aug 25,2016

Delhi ITAT remands comparability of Infosys and Wipro along with 7 other comparables, holds that comparable cannot be excluded merely based on precedents and comparability needs to be judged every

Aug 24,2016

Chennai ITAT rejects TPO's ALP-determination of interest rate on ECB from AE, based on effective all in cost interest rate as per ‘India's External Debt - Status Report - 2008', a document

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Aug 25,2016

Delhi ITAT upholds CIT(A) order excluding Celestial Biolabs as comparables for AY 2008-09 on grounds of functional dissimilarity with assessee providing software development services to its AE; Considers the functional

Aug 25,2016

ITAT rules on selection of comparables for assessee providing back office and call centre services to its AE, excludes Maple E-Solutions on grounds of tainted management reyling upon co-ordinate bench

Aug 24,2016

ITAT sets aside CIT(A) order confirming TP-adjustment for AY 2008-09 noting that CIT(A) merely dismissed assessee’s grounds without going into the merits of the case; States that CIT(A)’s order was

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ITAT: Payment for outsourcing to local affiliate by Indian-assessee not 'pass-through' for AE benchmarking

Chennai ITAT upholds TPO/DRP’s consideration of assessee’s (an Indian company) alleged ‘pass through cost’ while computing PLI of ITES services provided to overseas AE for AY 2009-10; Notes that assessee

Aug 22,2016

ITAT: Stresses on ‘hair-splitting’ level of FAR-analysis before embarking on comparables selection exercise

Delhi ITAT sets aside assessment order, directs TPO to carry out detailed FAR analysis in respect of assessee’s international transaction of provision of ITES to AE before embarking on comparables

Aug 23,2016

HC: Sets aside AO's domestic TP-reference, without reasoning, for donation to charitable-institution

Bombay HC sets aside order passed by AO making domestic TP assessment reference to TPO in respect of donation made by assessee to a charitable institution for AY 2013-14; HC

Aug 22,2016

ITAT: AE-credit period an international transaction though no price charged; Vodafone-ruling reference 'misplaced'

ITAT rules that allowing credit period for realization of marketing expenses from AE qualifies as an international transaction u/s 92B for AY 2007-08; Rejects assessee’s contention that transaction of extending

Aug 20,2016

HC: Confirms ITAT-order deleting corporate guarantee TP-adjustment absent actual pledging of shares

Gujarat HC rules that ITAT/ CIT(A) had rightly deleted TP-adjustment of Rs 3.65cr holding that assessee had not furnished corporate guarantee in favour of AE so as to be considered

Aug 22,2016

News

US Treasury lambasts EU for targeting American Cos, undermining BEPS consensus

US Treasury releases White Paper highlighting the implications and concerns of ongoing State aid investigations initiated by EU Commission (‘the

Aug 25,2016

BEPS a "sticking plaster", USA a sceptical participant: UK Parliamentary Group

The All-Party Parliamentary Group (‘APPG’), a UK group chaired by Margaret Hodge, releases report on examination of  OECD’s BEPS process /

Aug 16,2016

Sanjay Tolia appointed PwC APAC Transfer Pricing head

Sanjay Tolia appointed PwC APAC Transfer Pricing head, to also continue in his role as India TP practice leader

Aug 12,2016

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