ITAT: Sec 142(1) notice containing show-cause for ALP-determination constitutes sufficient notice u/s 92C(3)

Mumbai ITAT upholds validity of Sec 142(1) notice issued by AO for ALP-determination of assessee’s international transaction, rejects assessee’s plea that AO could not have made TP-adjustment

Aug 30, 2018

ITAT: Rejects NAV based ALP-determination for non-resident’s sale of Indian company shares

Delhi ITAT rejects TPO/DRP’s Net Asset Value (NAV) based ALP for benchmarking consideration for sale of shares in an Indian company by assessee (Singapore company) to

Aug 30, 2018

ITAT: Shilpa Shetty's free brand ambassadorship services to Rajasthan Royals outside TP-ambit, deletes adjustment

Mumbai ITAT deletes Rs.3.42cr TP-adjustment for Shilpa Shetty (assessee) for AY 2010-11 towards brand ambassadorship services rendered free of cost, rejects applicability of TP-provisions; Notes that assessee was

Aug 28, 2018

HC: Deletes Sec 271(1)(c) penalty considering assessee’s bonafide explanation for rejecting internal comparable

HC upholds ITAT-order deleting Sec 271(1)(c) concealment penalty for failure to consider internal comparable while applying CUP-method for ALP-determination in respect of AY 2006-07; Notes that there was

Aug 22, 2018

ITAT: Rejects Revenue's plea to apply higher APA-margin to earlier-AY absent assessee's rollback request

Mumbai ITAT rejects characterization of assessee’s non-binding investment advisory services as knowledge process outsourcing (KPO) for AY 2009-10, relies upon earlier year ruling; Directs inclusion of IDC

Aug 21, 2018

ITAT: Deletes Rs. 436 cr capital-gains addition on slump-sale, rejects FMV substitution invoking Sec 50D/92BA

Ahmedabad ITAT deletes Rs.436.80 cr. capital gains addition on transfer of wind energy business of Gujarat Fluorochemicals Ltd. (‘assessee’) on slump sale basis, rejects Revenue’s substitution of fair market value

Aug 16, 2018