Rulings

Sep 20,2018

Delhi ITAT rejects Microsoft India R&D's classification of its software segment as ‘routine software developer’ engaged only in testing & coding at lower level for its ultimate parent (Microsoft US),

Sep 12,2018

Karnataka HC upholds ITAT-order on comparables selection for ITeS-provider assessee for AY 2006-07; Upholds ITAT’s exclusion of Mercury Outsourcing Management by applying 10 times turnover range, rejects assessee’s reliance of Chryscapital

Sep 04,2018

Delhi HC allows assessee's writ, quashes final assessment order passed without issuing a draft order, however, directs AO to complete assessment u/s 144C in accordance with law; Pursuant to remand

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Sep 20,2018

Bombay HC dismisses Revenues appeal against ITAT order holding Motilal Oswal Investment Advisors  P Ltd as incomparable with assessee's non-binding investment advisory services'to its AE; Notes ITAT finding that Motilal

Sep 20,2018

Mumbai ITAT rules on selection of comparables for assessee engaged in rendering investment sub-advisory services to AE for AY 2011-12; Upholds exclusion of Motilal Oswal Investment Advisors Pvt. Ltd on grounds of functional dissimilarity as

Sep 20,2018

Delhi ITAT admits the additional evidence (audited accounts) filed by assessee in respect of its Software development and Software products segments for benchmarking international transaction of provision of software development

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ITAT: Microsoft’s 113 patentable inventions through software development in India clinches characterization as contract R&D

Delhi ITAT rejects Microsoft India R&D's classification of its software segment as ‘routine software developer’ engaged only in testing & coding at lower level for its ultimate parent (Microsoft US),

Sep 20,2018

HC: Upholds Tribunal’s remand of royalty benchmarking as not entirely ‘academic exercise’

Karnataka HC dismisses assessee’s appeal against ITAT-order remitting back royalty benchmarking for AY 2008-09; Notes that the need to remand the matter back to AO/TPO arose in view of the

Sep 17,2018

ITAT: Assessee/AO can’t change Tribunal’s specific directions on stay without approaching the bench

Bangalore ITAT refuses to take lenient view while disposing assessee's application for extension of stay, cites assessee's failure to inform Tribunal about not meeting condition of earlier stay order; Also

Sep 19,2018

ITAT: Remands isssue of TP-adjustment towards notional interest on delayed AE receivables

Delhi ITAT restores matter to AO/TPO with respect to TP adjustment for AY 2008-09 to 2010-11 towards notional interest on delayed AE receivable in light of the ratio of Delhi

Sep 18,2018

ITAT: Excludes 5 functionally dissimilar comparables for ITes- provider, Follows precedents

Delhi ITAT rules on selection of comparables for assessee providing ITeS to AE for AY 2010-11; Allows assessee’s plea for exclusion of 5 comparables on grounds of functional dissimilarity, absence

Sep 18,2018

News

Eye Share : OECD Discussion Draft on financial transactions - Decoding the Cash Pooling Enigma

Sachi Seksaria (Manager, Deloitte Haskins and Sells LLP), Kavita Sethia, and Kunal KadamThe OECD has begun to recognize the practical

Sep 19,2018

Karnataka HC Special - Part VII: Compilation of 21 rulings dismissing appeals on comparables & other issues following Softbrands

Compilation of rulings dismissing appeals on comparables & other issues following Softbrands ratioFollowing are 5 rulings where issues before Kar

Sep 14,2018

Eye Share : TP on domestic related party transactions – GAAR perspective

Hitesh Jain (Chartered Accountant and Senior Tax Professional)

Sep 14,2018

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