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

ITAT: Discards BLT for AMP-adjustment but allows AO to modify order post SC-outcome

Delhi ITAT rejects AMP-adjustment made by TPO/DRP in case of distributor-assessee by applying Bright Line Test for AY 2012-13, holds that “merely by applying the BLT, the existence

Nov 26, 2018

ITAT: Forex gain/loss recorded in books, not arising in subject-AY, relevant; Commscope ruling per-incuriam

Bangalore ITAT rules on treatment of forex gains/losses, write back of liabilities and selection of comparables for assessee engaged in contract software development services to its AE

Nov 23, 2018

ITAT: Deletes Rs141Cr TP-adjustment; Sale to non-AEs incomparable due to volume, geographical differences

Mumbai ITAT deletes Rs. 141. 13 Cr adjustment on export of goods in case of assessee engaged in manufacturing of aromatic ingredients, perfumery etc.; Rejects TPO's CUP method under

Nov 22, 2018

ITAT: Rejects re-characterization of Redeemable Preference Shares into loan; Stresses on ‘real-income’ principle

Delhi ITAT, in second round of proceedings, deletes notional interest adjustment on account of re-characterization of Redeemable Preference Shares (RPS) into loan & advances for AYs 2011-12 &

Nov 01, 2018