SC: Dismisses Revenue’s SLP; HC upheld CUP non-applicability for benchmarking royalty transaction

SC dismisses Revenue SLP against Rajasthan HC decision that had upheld ITAT-order deleting Rs.2.07cr TP-adjustment;  ITAT had upheld non-applicability of CUP-method on royalty payment to AE; HC had

May 09, 2018

ITAT: Accepts bona-fide nature of intra-group services; Remits benchmarking to follow Cushman ratio

Delhi ITAT sets aside CIT(A)’s order making Rs.83.79 lakhs TP-adjustment in respect of commission payment by assessee manufacturer for availing expert services from AE for AY 2008-09, remits

May 09, 2018

ITAT: Annual report terminologies not conclusive for proving facts, rejects comparables' R&D activity plea

Mumbai ITAT accepts assessee’s contentions to include Quintegra Solutions Ltd., RS Software India Ltd. and LGS Global Ltd as comparable for assessee’s software development services, rejects

May 09, 2018

ITAT: Excludes Thirdware as comparable for software-developer; Allows working capital adjustment claim

ITAT excludes Thirdware Solutions as comparable (on grounds of functional dissimilarity and absence of segmental details) for assessee engaged in provision of software development services to AE for

May 09, 2018

ITAT: Turnover differences “automatically ironed out” when average-PLI of comparables considered, follows Chryscapital-ruling

Delhi ITAT rules on selection of comparable for assessee providing IT & ITeS to AE for AY 2005-06; Accepts Revenue’s plea to include 3 comparables in IT Segment

May 08, 2018

ITAT: Onsite revenue an accepted filter for comparables selection; Upholds 3 comparables exclusion

Banglore ITAT rules on selection of comparables for assessee providing software development services to AE for AY 2011-12; Rejects Revenue’s contention against DRP’s suo-moto introduction of a new

May 08, 2018