ITAT: Upholds interest adjustment on delayed AE-receivables; Distinguishes earlier order in own case

Delhi ITAT upholds interest adjustment on delayed AE-receivables for assessee (engaged in executing engineering design and drawing for AEs) for AY 2012-13; Distinguishes assessee’s reliance on co-ordinate bench ruling

Jun 22, 2017

ITAT: Excludes ESOPs but includes unaccounted support services in operating-cost for software services

Bangalore ITAT remits computation of total cost for ALP-determination of software development services for fresh decision for AY 2003-04; Notes that AE provided certain fixed assets on free

Jun 21, 2017

HC: Construes objections dismissed on ground of delay as DRP-direction; Dismisses assessee’s writ

Madras HC dismisses assessee’s writ petition challenging DRP-order (refusing to condone assessee’s delay in filing objections before it) and consequent final assessment order by AO making the TP-adjustment

Jun 20, 2017

HC: Upholds LIBOR on interest-free advances to wholly owned subsidiaries, applies Tata Autocomp ratio

Bombay HC confirms ITAT order directing use of LIBOR + 2% as arm's length interest rate in respect of interest free advances given by assessee to its wholly

Jun 19, 2017

ITAT: Characterizes research & information service provider as KPO, advocates strict Rule 10B compliance

Delhi ITAT characterizes research and information services rendered by assessee to its AE as high-end knowledge-based research services (KPO), relies on decision in assessee's own case for earlier AY 2011-12 as well

Jun 16, 2017

HC: Admits Deloitte’s appeal challenging concealment penalty on disallowance of marketing cost reimbursement

Bombay HC admits appeal filed by Deloitte Consulting India (assessee) challenging penalty u/s 271(1)(c) on disallowance of reimbursement of marketing cost and denial of Sec. 10A benefit

Jun 16, 2017