HC: Dismisses writ citing alternate remedy; TPO can reconsider royalty rate, post remand

HC dismisses Hyundai Motor India’s writ challenging TPO’s order giving effect to ITAT’s order (in miscellaneous petition) on royalty TP-adjustment for AY 2008-09; Notes that ITAT had directed

Jul 30, 2018

ITAT: Deletes Sony's AMP-adjustment; Expenditure not for 'brand-building' but 'brand-maintenance' at best

Delhi ITAT, in second round of proceedings pursuant to HC remand, deletes AMP-adjustment of Rs.69.95cr for Sony Mobile (engaged in distribution of mobile handsets in India) for AY

Jul 27, 2018

HC: Stays TPO’s Sec 92CA(2) notice absent AO’s disposal of assessee’s objections to reassessment

HC rules of validity of notice issued by TPO before AO’s disposal of assessee’s objections to reassessment notice for AY 2007-08; Notes that pending AO’s disposal of assessee’s

Jul 23, 2018

HC: Sec 144C-procedure applicable even in remand cases; Quashes assessment without 'draft order'

HC allows assessee’s (a foreign company) writ, sets aside final assessment order passed u/s 143(3) without passing draft assessment order as mandated by DRP provisions u/s 144C(1) for

Jul 20, 2018

HC: Dismisses Revenue's appeal; ITAT-observation on TP-provisions inapplicability to tax-holiday unit not prejudicial

Karnataka HC dismisses Revenue's appeal against ITAT decision in Phillips Software Centre case for AY 2003-04; Holds that ITAT's observation that -TP-provisions were inapplicable to assessee entitled to tax

Jul 19, 2018

ITAT: Comparable inclusion despite earlier year exclusion, not mistake; Reconsideration u/s 254(2) not necessary

Mumbai ITAT holds that there was no mistake in its original order concluding Cybermate Infotek Ltd [CIL] as functionally comparable to low-end software developer assessee for AY 2012-13, but recalls

Jul 18, 2018

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