ITAT: Applies real income theory to delete TP-adjustment on transactions with JV

Mumbai ITAT reverses TPO/DRP’s order, deletes TP-addition in respect of non-interest bearing shareholder’s deposits in AE for AY 2012-13, notes that due to deteriorating financial position of assessee's

Oct 31, 2017

ITAT: Rejects challenge to CIT(A)'s royalty conclusion relied on subsequently, cites comity/amity doctrine

ITAT rejects Toyota Kirloskar’s attempt to challenge CIT(A)’s findings on ALP-determination of royalty payment by way of substantial appeal for AY 2005-06 noting that Tribunal had upheld CIT(A)’s

Oct 27, 2017

ITAT: Assessment order passed post HC-order falls u/s 153(6) ambit; Rejects assessee’s limitation plea

Mumbai ITAT dismisses assessee’s additional grounds for AY 2009-10 agitating that AO’s order dated January 16, 2015 u/s 144C r.w.s. 143(3) was time barred and thus bad in

Oct 26, 2017

HC: Dismisses writ, cannot examine DRP's refusal to restrict TP-adjustment sans facts

Madras HC dismisses assessee’s writ challenging enhancement by DRP whereby it directed AO not to restrict TP-adjustment to the proportion of international transactions to the total operating costs;

Oct 26, 2017

ITAT: ​TP-provisions applicable to insurance business; No role for Sec 44 in TP computation u/s 92

Delhi ITAT rules that provisions relating to transfer pricing u/s 92 apply to an assessee carrying on insurance business, rejects assessee’s contention that Sec 92 should not have

Oct 25, 2017

ITAT: Upholds TPO’s wide ranging employee-cost filter of 25-65%; Distinguishes Mentor-Graphics

Bangalore ITAT reverses CIT(A) order rejecting application of employee cost filter, upholds TPO’s application of wide ranging employee cost filter from 25% to 65% for AY 2007-08; Rejects

Oct 23, 2017