ITAT: IPO an extra-ordinary event, excludes IPO expenses for PLI computation; Remits 2 comparables

Mumbai ITAT remits comparability of 2 companies for benchmarking product development services rendered by assessee [engaged in business of import, wholesale trade, manufacture of drug and medicines and

Jun 13, 2018

AAR: MasterCard Interface Processor and MasterCard Network constitute fixed place PE in India

AAR rules that the Applicant (a Singaporean MasterCard group company) has a fixed place PE, service PE and dependent agent PE in India under Article 5 of the

Jun 13, 2018

ITAT: Deletes FCCDs interest adjustment sans any incriminating material found during search-proceeding

Delhi ITAT deletes interest adjustment on fully and Compulsory Convertible Debentures (FCCDs) issued by assesse [engaged in the business of manufacture and sale of electrical automobile components] pursuant to search

Jun 13, 2018

ITAT: Rejects 50% profit-attribution to Indian branch on HO's sales absent economic nexus

Delhi ITAT rejects AO’s attribution of 50% profits made by Corning SAS in France (AE), from direct sales made in India, to its India Branch office (BO) for

Jun 05, 2018

HC: Sets aside ITAT-order confirming royalty adjustment absent consideration of Sony, Siemens rulings

Karnataka HC sets aside ITAT-order confirming royalty adjustment for manufacturer assessee for AYs 2010-11 to 2012-13; Accepts assessee’s contention that ITAT upheld royalty adjustment [although royalty payment formed

Jun 04, 2018

ITAT: Deletes TP-adjustment on software purchase from AE; Rejects Nil ALP-determination of IP-rights

Hyderabad ITAT deletes TP-adjustment of Rs 69.40 Cr on assessee's (a LLP registered under Partnership Act, 1932) transaction of purchase of DSP Software and IP rights from Malaysian AE

Jun 01, 2018

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