ITAT: ‘Protective addition’ has no application to AMP-adjustment as BLT discarded by jurisdictional-HC

Delhi ITAT deletes AMP-adjustment of Rs. 23.83 cr made by TPO/DRP on protective basis for AY 2013-14; Notes that TPO had made ‘protective’ addition following Bright Line Test

Nov 20, 2017

ITAT: BMW's AMP-spend, international transaction, considering obligation to promote AE-brand; Distinguishes Maruti Suzuki

ITAT upholds existence of international transaction of AMP-expenses for BMW India for AY 2010-11, however, remits ALP-determination back to TPO directing examination of distribution & AMP ‘functions’ carried

Nov 14, 2017

ITAT: 2003-circular inapplicable to SDT; Upholds revision citing AO’s failure to verify SDT

Kolkata ITAT upholds CIT’s revisionary order u/s 263 on the ground that AO failed to verify specified domestic transactions [deduction u/s 80IB and payment to specified persons u/s

Nov 10, 2017

ITAT: Deletes Sec. 271G penalty; Jurisdiction transfer request reasonable cause for delayed information submission

Delhi ITAT reverses CIT(A)’s order, deletes penalty u/s 271G for failure of assessee to furnish details/documentation of international transactions (IT and ITeS services) within the time provided in the notice

Nov 10, 2017

HC: Dismisses Revenue’s appeal; Upholds aggregation of ESPN’s 'channel distribution' and 'advertisement-sale' segments

Delhi HC dismisses Revenue’s appeal, confirms ITAT-order upholding aggregation of ‘advertisement sale’ and ‘channel distribution’ segments for benchmarking purpose in case of ESPN Software India; ITAT, after noting that

Nov 10, 2017

ITAT: Deletes Sec. 271G penalty citing practical difficulty in information submission for diamond merchants

Mumbai ITAT dismisses Revenue’s appeal, upholds CIT(A)’s deletion of penalty u/s 271G imposed on assessees (diamond manufacturers & traders) for not complying with the statutory obligation cast upon it to

Nov 08, 2017