ITAT: Rejects TPO’s entity level benchmarking for international transactions; Follows HC-order in own case

Mumbai ITAT rejects TPO’s application of entity level approach for benchmarking assessee’s international transactions for AY 2009-10; Follows ruling in assessee’s own case for AY 2006-07 (subsequently upheld

Jan 19, 2018

ITAT: Fixes 0.5% as corporate guarantee ALP rate; Follows earlier order

Bengaluru ITAT determines ALP rate of guarantee fees at 0.5% in respect of corporate guarantee given to Mauritus-based AE by assessee (engaged in providing outdoor media

Jan 18, 2018

ITAT: Discards Revenue’s ‘unilateral’ adoption of entity-level benchmarking for software services; Follows precedents

Delhi ITAT rules against Revenue’s consideration of entity level margin under TNMM to determine ALP of its international transactions of providing software development services for AY

Jan 18, 2018

ITAT: Deletes profit attributed to assessee in connection with IPR-sale to AE; Follows precedent

Hyderabad ITAT deletes TP-adjustment of Rs.2.45cr as profit attributable under PSM to assessee (engaged in the business of providing animation production services for Television and Film Production Companies)

Jan 18, 2018

ITAT: Excludes functionally dissimilar ICRA-Online for investment advisor; Follows AGM-India ruling

Mumbai ITAT, pursuant to recall of Tribunal order for the limited purpose of adjudicating comparability of ICRA Online, rules on comparability of ICRA Online for assessee providing non-binding

Jan 18, 2018

ITAT: Includes 2 comparables for investment advisor; Remits comparability of ICRA-Techno, CRISIL

Mumbai ITAT rules on selection of comparables for assessee providing non-binding investment advisory services (‘IAS’) to AE for AY 2012-13; Accepts assessee’s contention to include ICRA Management Consulting

Jan 17, 2018

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