ITAT: Deletes AMP-adjustment for PepsiCo India absent brand building for AE; Follows earlier-order

Delhi ITAT deletes TP-adjustment of Rs.334.0617cr on account of Advertisement, Marketing and Promotion (“AMP”) Expenses for PepsiCo India for AY 2014-15; Notes that co-ordinate bench in assessee’s own

Jan 17, 2019

ITAT: Deletes TP-adjustment on outstanding AE-receivables applying Kusum Healthcare ruling ratio

Delhi ITAT deletes Rs.1.45 cr TP-adjustment towards interest on outstanding AE-receivables for assessee (engaged in IT enables network management and other back office supportservices to its Group Company & software development

Jan 17, 2019

ITAT: Adopts LIBOR/EURIBOR for benchmarking AE-loans lent in USD/EURO; Follows precedents

Mumbai ITAT accepts assessee’s plea, directs AO/TPO to determine the ALP of interest charged on the amounts advanced by the assessee to its AE in USD & EUROS

Jan 17, 2019

HC: Upholds LIBOR for benchmarking AE-loan & 0.5% as guarantee-commission ALP; Follows Everest Kanto

Bombay HC dismisses Revenue’s appeal, upholds ITAT’s adoption of LIBOR+2% as ALP for benchmarking interest in respect of foreign currency loan provided by assessee to its US subsidiary

Jan 17, 2019

ITAT: Adopts RPM over TNMM for benchmarking assessee’s trading activity; Follows earlier orders

Mumbai ITAT accepts assessee’s Resale Price Method (RPM) as MAM and rejects TPO’s TNMM for ALP-determination of the international transaction of import of seeds from

Jan 17, 2019

ITAT: Excludes 3 comparables for ITeS-provider and deletes TP-adjustment, Follows earlier orders

Mumbai ITAT deletes TP-adjustment in case of assessee engaged in providing Information Technology Enabled Back office service for AY 2008-09; Accepts assessee’s reliance on co-ordinate bench ruling in

Jan 15, 2019

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