HC: AO cannot make disallowance in final order beyond draft order variations/ DRP-enhancement

Madras HC confirms ITAT order for AY 2009-10, holds that AO exceeded the jurisdiction by making new disallowance while passing order u/s 144C(13) giving effect to DRP directions

Aug 18, 2017

ITAT: Includes ‘Kals’, ‘Accel Transmatics’ considering segmental data availability; Distinguishes precedents

Bangalore ITAT rules on selection of comparables for assessee providing software development services to AE for AY 2006-07; Rejects assessee’s plea to exclude ‘Aztec Software Systems’ & ‘Megasoft’

Aug 18, 2017

ITAT: Characterizes operational outsourcing services as low-end ITeS; Refers to Safe Harbour Rules

Delhi ITAT characterizes assessee’s operational outsourcing services to AE as low-end ITeS for AY 2012-13, refers to the definition of ITeS under the Safe Harbour Rules (‘SHR’) to

Aug 17, 2017

ITAT: Deletes penalty u/s 271BA considering assessee’s interpretation of Sec 92A provisions as ‘plausible view’

Mumbai ITAT deletes penalty levied by AO u/s 271BA for failure to furnish accountant’s report u/s 92E; Noting that levy of penalty u/s 271BA is subject to provisions

Aug 14, 2017

HC: Holds AO's order illegal and non-curable sans Sec.144C procedural compliance; Follows precedents

Gujarat HC upholds ITAT’s quashing of assessment order for AY 2009-10 making transfer pricing addition without following DRP procedure laid down u/s 144C, rejects Revenue’s contention that it was a

Aug 11, 2017

ITAT: Obligates assessee to demonstrate artificial expenses allocation in manufacturing segment not self-serving exercise

Pune ITAT rules on benchmarking of transactions in assessee’s manufacturing, trading and distribution activities (of intravenous ‘IV’ fluids) for AY 2008-09; In manufacturing segment, notes that TPO/DRP proposed adjustment

Aug 10, 2017

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