ITAT: Deletes corporate guarantee TP-adjustment; Remits ALP-determination of convertible debentures interest

Chennai ITAT deletes TP-adjustment in respect of corporate guarantee provided by assessee to AE for AY 2013-14; Follows co-ordinate bench ruling in assessee’s own case in AY 2009-10

Apr 02, 2018

ITAT: Holds draft assessment order passed alongwith demand notice as ‘invalid’; Follows earlier-order

Pune ITAT, admits assessee’s additional ground, holds that draft assessment order passed along with issue of a demand notice is a complete order which is not envisaged under

Apr 02, 2018

ITAT: Upholds Infosys Technology exclusion for software developer assessee; Follows Agnity ruling

Delhi ITAT upholds exclusion of Infosys Technology Ltd as comparable for assessee providing software development services to AE for AY 2008-09; Notes that this company had huge turnover

Apr 02, 2018

ITAT: Remits TP-issues to consider assessee’s additional evidence; Follows earlier years’ approach

Bangalore ITAT sets aside DRP’s order, remits matter back to AO/TPO to re-adjudicate TP-issues after considering additional evidence filed by assessee for AY 2013-14; Notes that assessee could

Apr 02, 2018

ITAT: Rejects Tribunal’s direction on 25%-RPT application considering filter already applied by TPO

Bangalore ITAT, allows assessee’s miscellaneous petition for AY 2010-11, deletes direction given to TPO to bring in more comparables functionally similar to the assessee after applying 25% RPT filter

Mar 29, 2018

ITAT: Allows FactSet to withdraw appeal against TP-adjustment considering resolution under APA

Hyderabad ITAT allows FaceSet Systems India to withdraw appeal on TP-issues in view of resolution under APA; Notes that APA was concluded on February 23, 2018 and subject

Mar 29, 2018

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