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

HC: Upholds LIBOR+2% as interest-ALP for loan to Mauritius AE; Follows Aurinpro ruling

Bombay HC dismisses Revenue’s appeal against ITAT’s application of LIBOR plus 2% interest for benchmarking interest on loan granted by assessee to AE for AY 2009-10; Notes that

Jul 09, 2018

SC: Admits SLP against HC-order confirming adjustment to ALP for Forex fluctuation

SC admits Revenue's SLP against Delhi HC order allowing adjustment for foreign currency fluctuations while working out TP-adjustment for AY 2009-10; HC had dismissed Revenue's appeal noting that ITAT, after

Jul 09, 2018

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