Rulings

Nov 21,2017

Pune ITAT rejects AO/DRP’s curtailment of deduction u/s 10A for assessee’s engineering design services division applying provisions of Sec 10A(7) r.w.s. 80IA(10) absent arrangement between the parties to earn more than

Nov 20,2017

Delhi ITAT deletes AMP-adjustment of Rs. 23.83 cr made by TPO/DRP on protective basis for AY 2013-14; Notes that TPO had made ‘protective’ addition following Bright Line Test (BLT) as

Nov 14,2017

ITAT upholds existence of international transaction of AMP-expenses for BMW India for AY 2010-11, however, remits ALP-determination back to TPO directing examination of distribution & AMP ‘functions’ carried out by

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Nov 21,2017

Chandigarh ITAT stays tax demand (including interest and other charges) of Rs. 64.48cr subject to deposit of 5% of demand by assessee within 15 days from the date of order for AY

Nov 21,2017

Delhi ITAT sets aside CIT(A)’s order deleting TP-adjustment without giving reasons for taking average of multiple year data for computing PLI of comparables for AY 2005-06; Dismisses assessee’s contention that

Nov 21,2017

Delhi ITAT allows Revenue’s appeal, includes Ultramine & Pigments Ltd as comparable for assessee providing ITES to AE for AY 2005-06; Relying on Delhi HC’s Chryscapital ruling (wherein it was held

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ITAT: ‘Protective addition’ has no application to AMP-adjustment as BLT discarded by jurisdictional-HC

Delhi ITAT deletes AMP-adjustment of Rs. 23.83 cr made by TPO/DRP on protective basis for AY 2013-14; Notes that TPO had made ‘protective’ addition following Bright Line Test (BLT) as

Nov 20,2017

ITAT: Deletes protective AMP-adjustment, discards bright line test; Follows Sony & earlier orders

Delhi ITAT deletes AMP-adjustment in respect of assessee (engaged in business of import, distribution and sales of ‘Nikon Imaging Products’ in India) for AY 2013-14; Notes that TPO proposed AMP intensity adjustment

Nov 16,2017

HC: Mere disagreement about TP-methods does not ipso-facto constitute question of law

Delhi HC dismisses Revenue’s appeal against ITAT-order in case of MCCain Foods India affirming RPM as MAM; Notes that RPM selected as MAM by assessee was rejected by TPO who

Nov 15,2017

HC: Restores AMP-adjustment back to ITAT for de-novo adjudication following earlier order

Delhi HC partially allows assessee’s appeal against ITAT-order holding incurrence of AMP-expenses to be an international transaction for AY 2011-12; Further, notes that ITAT had remitted ALP-determination of AMP-expenses back

Nov 15,2017

ITAT: Rejects Sec 10A-deduction curtailment; AO cannot re-examine transaction once ALP accepted by TPO

Pune ITAT rejects AO/DRP’s curtailment of deduction u/s 10A for assessee’s engineering design services division applying provisions of Sec 10A(7) r.w.s. 80IA(10) absent arrangement between the parties to earn more than

Nov 21,2017

News

OECD's EOI report rates India ‘largely compliant’, recommends improvements in request quality

OECD’s Global Forum publishes 6  peer review reports (including India) on the Standard of transparency and exchange of information on request, bringing

Nov 21,2017

Proposed UN sub-committee on Article 9 includes 2 Indians; Mandates work on TP-Manual update

Taxsutra learns that 2 Indians, Rajat Bansal (Joint Secretary, Ministry of Finance) & leading tax expert TP Ostwal, are likely to

Nov 10,2017

Final & draft CbCR Rules largely similar; Prescribes TT buying rate for Forex conversion

Final CBCR and Master File Rules largely similar to draft Rules except for changes in Form No and other minor

Nov 01,2017

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