ITAT: Dismisses McDonald’s appeal on TP-grounds in view of resolution under MAP

Delhi ITAT dismisses McDonald’s India’s TP-grounds for AYs 2010-11 & 2011-12 as not pressed, in view of resolution under MAP; Noting that assessee did not press the grounds

Jul 10, 2018

ITAT: Quashes assessment citing failure to follow CBDT Instruction 3/2003; Follows Calance Software ruling

Delhi ITAT allows assessee's additional ground, quashes assessments and deletes TP-adjustment for AY 2007-08 and 2008-09; Holds that since the value of assessee's international transactions was below Rs. 5

Jul 10, 2018

ITAT: Deletes TP-adjustment on support services; No mark-up required on third-party costs

Delhi ITAT deletes TP-adjustment for AY 2008-09 on support services provided to AE by assessee engaged in trading /servicing of Automatic Bank Note Sorting Machines; Notes that assessee had

Jul 10, 2018

ITAT: Adopts profit before depreciation as PLI, distinguishes earlier-order; Upholds 2 comparables exclusion

Bangalore ITAT allows assessee’s plea, directs AO/TPO to consider margin after excluding depreciation in case of assessee & comparables for AY 2011-12; Follows DRP’s direction in assessee’s own

Jul 09, 2018

ITAT: Rejects seafood exporter's claim for adjustment to CUP absent data substantiating claim

Cochin ITAT dismisses assessee's appeal against Revenue's denial of 3% adjustment to comparable uncontrolled price (CUP) claimed by assessee in respect of its sale of seafood products to

Jul 09, 2018

ITAT: Exclude 10 companies as comparable for captive ITeS service provider; Follows judicial precedents

Delhi ITAT rules on comparables selection for Captive ITeS Service provider for AY 2008-09, follows Tribunal ruling in assessee’s own case for AY 2007-08 and Symphony Marketing Solutions

Jul 09, 2018