ITAT: ITAT asks DRP to reconsider its order

Non-speaking DRP order sent back to DRP for re-consideration by Delhi ITAT

Feb 07, 2011

ITAT: Whirlpool USA’s India Branch did not create PE

Branch in India set-up by Whirlpool USA to protect and safeguard the interest of parent company in India; Did not create a Permanent Establishment (PE) 

Jan 27, 2011

ITAT: Transfer pricing – 5% variation from arithmetic mean

Transfer pricing – 5% variation from arithmetic mean - Benefit not available where only one arm’s length price is determined

Jan 27, 2011

ITAT: Income-tax WDV of assets to be adopted as ALP in case of transfer of business to AE

Transfer value of the assets of Indian branch of foreign company to be determined by applying income tax depreciation rates

Jan 27, 2011

ITAT: Transfer pricing mark-up was not required on incentive payment to Indian employees by the associated enterprise

The Delhi bench of ITAT held that incentive payments made by the overseas AE to the employees of the assessee company in India did not have “income” element in the

Jan 21, 2011

ITAT: Transfer pricing - 5% variation from arithmetic mean

Benefit of 5% deviation is not available where only one arm's length price is determined

Jan 17, 2011

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