ITAT: Discards Revenue's geographical, FAR differences plea between domestic-exports segments for rejecting internal-comparables

Pune ITAT rules on selection of MAM and use of internal comparables for benchmarking export and import transactions of assessee (manufacture of heavy commercial vehicles) for AY 2009-10;

Apr 10, 2018

ITAT: TP-provisions applicable to Indian branch’s brand promotion transaction; Rejects mutuality principle applicability

Delhi ITAT rules on TP-adjustment in respect of AMP-expenses incurred by Indian Branch to promote brand name of ‘FUJI’ in India for AY 2007-08 & 2008-09, rejects assessee’s

Apr 06, 2018

ITAT: Quashes revision, AO-order without TPO-reference not erroneous; Statute overrides Circular when contrary

Lucknow ITAT quashes revisionary jurisdiction assumed by Pr.CIT u/s 263 on the sole ground that as per CBDT Instruction 3/2016, mandatory reference was not made by AO to

Apr 04, 2018

HC: Upholds TNMM for AE-exports and sales commission; Considers ITAT’s view as reasonable

Bombay HC dismisses Revenue’s appeal, holds that ITAT was justified in holding TNMM as MAM for benchmarking exports to AEs for AYs 2006-07, 2007-08 & 2008-09; Notes that TPO made

Mar 30, 2018

ITAT: CBDT Instruction No.3/2003 binding, quashes TPO-reference where international transaction quantum < 5cr for AY 2006-07

Delhi ITAT allows assessee’s additional ground, quashes AO’s reference to TPO for AY 2006-07; Holds that as per CBDT Instruction 3/ 2003, AO should have decided the issue

Mar 28, 2018

ITAT: Irrecoverable interest-free loan to AE impacts profitability, excludes "Informed Technologies" as comparable

Cochin ITAT rules on selection of comparables for assessee providing business support services & ITeS to AE for AY 2012-13; Accepts assessee’s contention to exclude Infosys BPO and

Mar 27, 2018