ITAT: Deletes Nivea’s AMP-adjustment; Explains ‘subtle but definite difference’ between product & brand promotion

Mumbai ITAT deletes TP-adjustment on Advertising, Manufacturing and Publicity (AMP) expenses incurred by Nivea India during AYs 2008-09 to 2012-13 absent any agreement/arrangement with AE for incurring of

Mar 26, 2018

ITAT: Deletes TP-adjustment on intra-group services, availment & basis of charge established

Pune ITAT deletes TP-adjustment for AY 2008-09 on information technology (IT) services availed by assessee (engaged in manufacture and distribution of fluid power equipment) holds that factum of

Mar 22, 2018

HC: Upholds ITAT-order allowing overhead expense allocation by JV-partners to assessee AOP

Bombay HC upholds ITAT’s order quashing TPO's disallowance of overheads allocated by JV partners to assessee (an AOP with 5 members formed for executing contract for Delhi Metro Rail

Mar 21, 2018

SC: Re-assessment initiation based on PE allegation not sustainable once arm's-length threshold met

SC allows Honda Motor’s (a Japanese company) appeal and sets aside Allahabad HC ruling, quashes issuance of re-assessment notice; HC had dismissed assessee’s writ and had

Mar 20, 2018

ITAT: Rejects assessee's aggregated benchmarking of royalty under TNMM, confirms sales commission TP-adjustment

Delhi ITAT rejects assessee’s aggregated approach for benchmarking royalty payment to UK based AE under TNMM for AY 2007-08 to 2009-10, upholds external CUP as most appropriate method

Mar 20, 2018

ITAT: Allows Sec 10A deduction on voluntary TP-adjustment; Follows iGate over Deloitte ruling

Pune ITAT rules that assessee is entitled to Sec 10A deduction on additional income offered on account of suo-moto TP-adjustment for AY 2011-12; Notes that TPO/ CIT(A) disallowed

Mar 16, 2018