HC: Upholds ITAT-order; Sister-in-law neither 'associated' nor 'relative' u/s 92A

Rajasthan HC dismisses Revenue’s appeal against ITAT-order holding that assessee & India Gems & Beads were not associated enterprises u/s 92A; ITAT had rejected Revenue’s contentions that since

Nov 03, 2017

HC: Upholds ITAT’s comparables selection for software developer; Hewlett-Packard ruling not ‘blindly’ followed

Delhi HC dismisses Revenue’s appeal challenging ITAT’s exclusion of comparables for assessee providing software development services to AE for AY 2007-08, also rejects Revenue’s contention that assessee was

Nov 03, 2017

ITAT: TP-adjustment doesn't automatically indicate lack of due diligence & good faith; Deletes penalty

Delhi ITAT deletes concealment penalty levied with respect to TP-adjustments for AY 2010-11 for assessee engaged in infrastructure consultancy, relies upon ITAT ruling in RBS Equity India Ltd;

Nov 03, 2017

ITAT: Outstanding AE-receivables = ‘capital financing’, qualifies as ‘international transaction’; Distinguishes Ameriprise, Bechtel HC-rulings

Delhi ITAT rules that outstanding AE-receivables constitute an ‘international transaction’ for AY 2009-10 & 2010-11, holds that “the receivable or any other debt arising during the course of the

Nov 03, 2017

ITAT: Quashes assessment absent valid TPO-reference; Mentioning international transactions in reference, must

Kolkata ITAT quashes assessment orders for AYs 2009-10 & 2010-11 as being barred by limitation u/s 153(1) absent valid reference by AO to TPO u/s 92CA(1); Noting that Revenue

Nov 03, 2017

ITAT: Extra credit-period, separate international transaction; Rejects reliance on Kusum HC-ruling

Bangalore ITAT rules that extra credit period allowed to AEs beyond the agreed credit period (30 days in present case) amounts to an independent international transaction requiring separate

Nov 01, 2017