HC: Upholds ITAT’s exclusion of 5 comparables for marketing support service provider

Delhi HC dismisses Revenue's appeal against ITAT order on comparable selection for assessee engaged in provision of market support services to AE for AY 2009-10; Notes that ITAT

Jan 15, 2019

ITAT: Restricts guarantee commission ALP to 0.5%; Follows Everest Kento HC ruling

Mumbai ITAT restricts guarantee fee ALP at 0.5% in respect of corporate guarantee provided by assessee on behalf of its AE (Virgo Europe S.P.A. Italy [VES]) for availing

Jan 15, 2019

ITAT: Rejects CIT(A)’s LIBOR adoption for benchmarking CCD interest; Remits issue for fresh examination

Bangalore ITAT remands to CIT(A), issue of TP-adjustment on account of interest paid on Compulsorily Convertible Debentures (CCDs) issued by assessee (engaged in construction, real estate and plotted

Jan 15, 2019

ITAT: Accepts RPM over TNMM for trading operations without value addition; Follows precedents

Bangalore ITAT upholds assessee's RPM as Most Appropriate Method (‘MAM’) over TPO’s TNMM to compute ALP of trading segment (involving importing of high technology precision cutting tools) for

Jan 15, 2019

ITAT: Directs inclusion of segmental results for Megasoft while computing PLI for software segment

Bangalore ITAT, while adjudicating on the recalled ITAT-order vide miscellaneous petition dated 06.07.2018 for AY 2007-08, upholds Megasoft Ltd as comparable for assessee's software development segment; Relies upon

Jan 15, 2019

ITAT: Determines corporate-guarantee fee ALP at 1%, Holds Tega Industries ruling per incuriam

Kolkata ITAT allows Revenue’s plea challenging deletion of adjustments on account of corporate guarantee given by assessee on behalf of its US based AE for AYs 2011-12 and

Jan 15, 2019