ITAT: Upholds Sec 263-order absent AO’s mandatory TPO-reference as per CBDT Circular 3/2016

Mumbai ITAT upholds Pr. CIT’s order u/s 263 for AY 2015-16, confirms AO’s assessment order to be erroneous & prejudicial to Revenue’s interest absent AO’s reference of TP

Dec 11, 2018

ITAT: Rejects assessee's Nil interest-ALP for stressed AE-loans citing commercial expediency, revenue neutrality

Mumbai ITAT rejects assessee’s (engaged in the business of outdoor media advertising services) Nil ALP-determination of loans granted to AEs on the basis that their recovery was doubtful

Dec 07, 2018

ITAT: TPO cannot arbitrarily interfere with PLI-selection; Sec 41(1)-waiver irrelevant for intra-group services benchmarking

Delhi ITAT rules on selection of comparables, MAM, PLI and grant of capacity adjustment in manufacturing segment of assessee (engaged in manufacturing products to be assembled in the

Dec 06, 2018

ITAT: Deletes Rs.2800cr+ AMP-adjustment for PepsiCo, a full-fledged manufacturer; Rejects PSM/BLT for benchmarking

Delhi ITAT deletes AMP-adjustment for Pepsi Co India (full-fledged manufacturer) for AYs 2006-07 to 2013-14, holds that firstly, there is no international transaction in the form of any

Dec 04, 2018

SC: Dismisses Revenue’s SLP against HC-order upholding 25% RPT-filter application & Wipro exclusion

SC dismisses Revenue’s SLP against HC order upholding application of 25% RPT filter & exclusion of Wipro Ltd for comparability analysis for AY 2007-08; HC had opined that RPT filter is

Dec 04, 2018

ITAT: Holds market quotations from internet as “unreliable CUP” for benchmarking AE-exports

Delhi ITAT rules on TP-adjustment on export of stainless steel, interest on loan and corporate guarantee provided by steel manufacturer to its AEs for AYs 2007-08 and 2008-09;

Nov 26, 2018