HC: Upholds ITAT’s rejection of Revenue’s appeal against DRP’s revised-order for pre-2012 objections

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

Jan 16, 2019

HC: Directs no demand enforcement / refund adjustment w.r.t. Sony’s AMP-adjustment till ITAT’s appeal-disposal

Delhi HC directs Revenue not to enforce TP-demands arising pursuant to AMP-adjustment by applying intensity test for AY 2013-14, also directs no adjustment of refund amounts due &

Jan 16, 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

Jan 15, 2019

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

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

HC: Upholds PE-constitution for 24 GE Group entities, affirms 26% profit-attribution for ‘marketing’ activity

Delhi HC confirms ITAT order upholding constitution of fixed place PE as well as dependent agent PE (‘DAPE’) for 24 GE group entities in a batch of appeals

Jan 09, 2019