ITAT: Upholds TPO’s aggregation of ITES, software segments; Deviates from earlier years' approach

Delhi ITAT upholds TPO’s aggregation of ITES and software development services (SDS) for benchmarking under TNMM absent assessee’s substantiation for bifurcation of the segments for AY 2013-14; Observes

Feb 20, 2018

ITAT: Renault India's transaction with Renault Nissan India, not international transaction; Deletes Rs. 178 cr adjustment

Chennai ITAT deletes TP-adjustment of Rs. 178 Cr in case of Renault India (assessee) for AY 2012-13, holds that transaction of purchase of cars from a resident entity

Feb 17, 2018

HC: RPT-filter essential to avoid "distorted picture" of profitability due to excessive AE-transactions

Delhi HC upholds ITAT’s application of 25% RPT filter for comparability analysis in case of Oracle (OFSS) BPO Services for AY 2007-08; Stating that RPT filter “is relevant

Feb 12, 2018

AAR: Mauritian company's control & management not with US Holding Co.; Grants Capital gains exemption

AAR holds that capital gains arising on proposed sale of shares in Indian entity (ABInternational) by Applicant (a Mauritian entity) is not chargeable to tax in India under

Feb 09, 2018

HC: Quashes Daimler's re-opening noting Form 3CEB disclosure; Onus on AO to peruse TPO's order

Madras HC allows Daimler India's writ, quashes re-assessment proceedings initiated after the expiry of 4 years from the end of the relevant AY 2009-10, holds that it was

Feb 09, 2018

ITAT: Non-monetary aspects important for judging benefit test; Rejects license, management fees Nil-ALP

Bangalore ITAT rejects TPO’s Nil ALP-determination under CUP-method in respect of payment of license and management fees by assessee (JV engaged in manufacture of pharmaceutical formulations) to AE

Feb 06, 2018