ITAT: Remits ALP issues as necessary details/computation not confronted to AO/ TPO

Delhi ITAT sets aside CIT(A) order granting relief with respect to TP adjustment on exports and imports from AE for assessee engaged in manufacturing diamond tools and

Sep 14, 2018

ITAT: Restores ALP-determination of management fee payment to AE; Follows earlier-orders

Bangalore ITAT restores ALP-determination of assessee’s management fee payment to AE for AY 2012-13; Notes that TPO determined ALP as Nil and consequently disallowed the entire management fee

Sep 14, 2018

ITAT: Remits directors-remuneration expenditure falling under erstwhile specified domestic transaction provisions; Follows precedent

Bangalore ITAT remits assessee’s claim of expenditure relating to payment of remuneration of directors (which fell under the erstwhile specified domestic transactions provisions under clause (i) of Sec. 92BA) back

Sep 14, 2018

ITAT: Admits additional evidence, remits ALP-determination for management service from AE

Pune ITAT admits additional evidence with respect to TP adjustment towards management service fees paid to AE for AY 2011-12; Notes that the management service fees were disallowed

Sep 12, 2018

ITAT: Remits ALP-determination of intra-group services; Relies upon Cushman Wakefield ruling

Delhi ITAT sets aside TP-adjustment on assessee’s (engaged in manufacturing and marketing of lubricants) international transaction of receipt of business support services for AY 2010-11, remits

Sep 12, 2018

ITAT: Rules on comparables for data processing and data entry services, follows precedents

Delhi ITAT rules on selection of comparables for assessee’s data processing and data entry services to AE for AY 2010-11; Accepts assessee’s plea to exclude 9 comparables

Sep 12, 2018