ITAT: Directs AO to follow DRP direction restricting adjustment to Group's consolidated profit 

ITAT directs AO to recompute adjustment by adhering to directions of DRP; Every direction issued by DRP binding on AO u/s 144(10); DRP directed AO to restrict TP addition to

May 02, 2014

ITAT: Reiterates giant companies not comparable; Excludes Eclerx, Moldtek relying on SB ruling 

ITAT upholds CIT(A)’s order excluding giant companies like Infosys BPO Ltd., Wipro Ltd; Relies on consistent view of Hyderabad bench in Capital IQ Information Systems and Market Tools P Ltd;

Apr 29, 2014

ITAT: Directs TPO to re-examine comparability of Infosys considering Agnity ruling 

Inclusion of Infosys Technologies Ltd as comparable prima facie incorrect due to its diversified services, ownership of proprietary products, spend on R&D, brand building, difference in revenue, etc.; Directs TPO

Apr 29, 2014

ITAT: Assessee's import not "arranged transaction", deletes addition citing earlier favourable order

Deletes addition u/s 92 on purchase of raw material (cefotaxime sodium & roxythromycin) from related party; Transaction between assessee & non-resident company not an “arranged transaction”; Assessee did not buy

Apr 29, 2014

ITAT: Selling expenditure not part of AMP expenditure for computing marketing intangible adjustment 

TPO to determine marketing intangible adjustment afresh in light of Special Bench ruling in LG Electronics; Special Bench upheld assessee’s contention that expenses directly connected with sales should be excluded

Apr 25, 2014

ITAT: Directs exclusion of selling expenditure AMP expenditure; Follows LG Electronics SB ruling 

Following Special Bench ruling in LG Electronics, ITAT accepts assessee’s contention to exclude selling expenses such as selling commission, discount from AMP expenses; LG Electronics ruling applies to manufacturer as

Apr 25, 2014

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