ITAT: DRP proceedings a continuation of assessment, additional evidence consideration a must

Pune ITAT sets aside DRP order rejecting admission of additional evidences filed by assessee to support its contention that its foreign AE can be selected as tested party

May 18, 2018

ITAT: Grants partial adjustment for extra-ordinary costs, emphasizes need to demonstrate with evidence

Delhi ITAT holds that any claim to treat expenditure as extra-ordinary and not arising in normal course of business "needs to be demonstrated with strict evidence”; Upholds CIT(A)’s allowance of

May 17, 2018

ITAT: Upholds CUP citing AE-customer transaction at same price, without value addition

Kolkata ITAT deletes TP-adjustment of Rs. 100.29 crores in respect of export of printed circuit boards (PCBs) by assessee to its AE in Austria [for further sale in Europe as

May 14, 2018

ITAT: Directs aggregation of Google India's Adwords & ITeS transactions; Adopts PSM as MAM

Bangalore ITAT remits Google India’s functional characterization for TP purpose for AYs 2009-10, 2010-11 & 2011-12, directs TPO to aggregate functions (like ITeS) which have a direct nexus

May 11, 2018

ITAT: Quashes TP-adjustment; AO's reassumption of jurisdiction after TPO-reference would lead to 'anarchy'

Jodhpur ITAT deletes TP-adjustment of Rs.113.53 cr for AY 2012-13, holds AO’s re-assumption of jurisdiction to determine ALP of assessee’s international transactions, where reference was already made to

May 10, 2018

ITAT: Cannot select AE as tested party absent data to demonstrate FAR analysis

Delhi ITAT upholds TP-adjustment on assessee’s international transaction of purchase of raw material and components, rejects assessee’s consideration of foreign AE as tested party for AY 2012-13;

May 10, 2018