ITAT: Outstanding AE-receivables pre-2012 amendment, not an ‘international transaction’; Deletes TP-adjustment

Jaipur ITAT confirms CIT(A)’s deletion of notional interest adjustment in respect of outstanding AE-receivables for assessee (engaged in manufacturing cut and polished diamonds) for AYs 2007-08 to 2009-10;

Dec 04, 2017

ITAT: Rules on computation of ‘Wages’ and ‘Sales’ component of employee-cost filter

Delhi ITAT, in second round of proceedings, rules on selection of comparables by applying filter of ‘wages to sales ratio’ for assessee providing software development services for

Dec 04, 2017

ITAT: Upholds royalty & managerial services aggregation under TNMM; Rejects Revenue's FEMA reliance

Chennai ITAT deletes TP-adjustment in respect of assessee’s royalty payment to AE for availing technology, also deletes in-principle TP-adjustment in respect of payment of management services fee to AE

Nov 29, 2017

ITAT: Sec 153(2A) limitation applicable despite one of multiple issues remanded; Follows Nokia ruling

Delhi ITAT, in second round of proceedings, quashes AO’s final assessment order as barred by limitation u/s 153(2A) and Sec. 144C(13) for AY 2008-09; Notes that pursuant to

Nov 28, 2017

ITAT: Deletes concealment penalty despite no proper benchmarking; Cites nascent stage of TP-regulations

Mumbai ITAT quashes Sec 271(1)(c) penalty imposed on assessee in respect of disallowance of cost allocation of management fees which was not carried in further appeal before Tribunal

Nov 23, 2017

ITAT: Rejects Sec 10A-deduction curtailment; AO cannot re-examine transaction once ALP accepted by TPO

Pune ITAT rejects AO/DRP’s curtailment of deduction u/s 10A for assessee’s engineering design services division applying provisions of Sec 10A(7) r.w.s. 80IA(10) absent arrangement between the parties to earn

Nov 21, 2017