ITAT: Manpower underutilization linked to capacity adjustment; Rejects modification to ITAT-order remitting issue

Bangalore ITAT partly allows assessee’s miscellaneous petition, modifies ITAT order pertaining to AY 2006-07 to exclude Mega Soft Ltd as a comparable in place of Lanco Global Solutions

Jun 23, 2017

ITAT: Remits AMP-issue related to selling, distribution for fresh adjudication following earlier order

Delhi ITAT remits TP-adjustment in respect of AMP-expenses related to selling and distribution activities for MSD Pharmaceuticals for AY 2011-12; Follows co-ordinate bench ruling in assessee’s own case

Jun 21, 2017

ITAT: Quashes assessment on non-existent amalgamating company; Follows Spice Entertainment HC-ruling

Delhi ITAT quashes assessment framed in the name of non-existent amalgamating company for AY 2006-07; Notes that pursuant to Karnataka HC order for merger (dated January 9, 2009),

Jun 21, 2017

ITAT: Remands entire comparability issue for fresh examination after admitting assessee’s additional ground

ITAT rules on selection of comparables for Moog Controls India for AY 2008-09; Admits assessee’s additional ground for exclusion of 2 comparables (Lucid Software Ltd and Bodhtree

Jun 21, 2017

HC: Dismisses Revenue’s appeal challenging +/-5% benefit; Can’t agitate new grounds before HC

Bombay HC dismisses Revenue’s appeal challenging ITAT decision deleting TP-adjustment as transaction price was within +/-5% range of ALP; HC holds “The grounds which were never agitated before

Jun 19, 2017

ITAT: Adjudicates comparables selection for Disney Group company; Remands comparable with fluctuating margins

Mumbai ITAT rules on selection of comparables in respect of ‘content supply and support services’ and ‘general management services’ rendered by assessee (Disney Group company) to its AEs

Jun 19, 2017