HC: Sets aside ITAT-order confirming royalty adjustment absent consideration of Sony, Siemens rulings

Karnataka HC sets aside ITAT-order confirming royalty adjustment for manufacturer assessee for AYs 2010-11 to 2012-13; Accepts assessee’s contention that ITAT upheld royalty adjustment [although royalty payment formed

Jun 04, 2018

ITAT: Deletes TP-adjustment on software purchase from AE; Rejects Nil ALP-determination of IP-rights

Hyderabad ITAT deletes TP-adjustment of Rs 69.40 Cr on assessee's (a LLP registered under Partnership Act, 1932) transaction of purchase of DSP Software and IP rights from Malaysian AE

Jun 01, 2018

ITAT: Market survey benefited assessee, cannot be equated with shareholders’ activity; Deletes TP-adjustment

Delhi ITAT deletes TP-adjustment made in respect of BMW India’s payments on account of market survey and technical support services to its AE, BMW AG, for AY 2007-08; In respect

May 31, 2018

ITAT: Daikin's Indian subsidiary constitutes DAPE; Attributes profits, TP-analysis not adequately reflecting FAR

Delhi ITAT rules that the wholly owned Indian subsidiary of Daikin Industries Ltd. (assessee, a Japanese company), constitutes assessee’s dependent agent PE for AY 2006-07; Holds that

May 30, 2018

ITAT: Averages don’t always give logical results; Rejects bank quotes average as guarantee ALP

Kolkata ITAT directs adoption of 0.25%, based on free quote given by Royal Bank of Scotland (RBS), as ALP for provision of corporate guarantee by assessee to AEs

May 23, 2018

ITAT: Rejects entity level benchmarking, assessee’s domestic segment not extension of international business

Mumbai ITAT rejects TPO’s entity wide approach for benchmarking international transactions in respect of International Express and International Freight Forwarding segments of assessee [engaged in the business of

May 21, 2018

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