ITAT: Insignificant transaction volume no ground for rejecting internal-comparables, follows Lummus, Tecnimont rulings

ITAT rules on adoption of internal comparables in preference to external comparables in case of assessee’s software development services transaction with AE; Notes assessee maintained segmental details of

Jul 10, 2015

ITAT: Excludes 18 of 26 comparables on turnover-filter, functional dissimilarity with software service-provider

ITAT rules on selection of comparables for assessee engaged in providing software development services to AE for AY 2007-08; Holds ITAT ruling in Broadcom India case applicable as

Jul 10, 2015

ITAT: Dismisses old TP-appeals, adjudication academic as 8-year loss carry-forward period elapsed

ITAT dismisses cross appeals filed by assessee and Revenue relating to AYs 2002-03 & 2003-04; Appeals related to TP adjustment on transactions of import of spare parts and

Jul 09, 2015

ITAT: Cost-plus MAM for contract manufacturer; Allows adjustment for comparables' additional selling expenses

ITAT upholds CIT(A) order, holds Cost Plus Method (CPM) as Most Appropriate Method (MAM) for contract manufacturers, rejecting assessee’s alternate application of TNMM; Assessee contended that in choosing

Jul 09, 2015

ITAT: Excludes functionally dissimilar companies, applies Rs 200 cr turnover and 15%-RTP filter, follows Ariba ruling

ITAT rules on selection of comparables for assessee engaged in business of providing software development services to AE for AY 2006-07; Relies on co-ordinate bench ruling in Ariba

Jul 09, 2015

ITAT: Remits royalty benchmarking for acceptance of fresh comparables, follows earlier AY order

ITAT sets aside AO’s order for AY 2008-09, remits royalty transaction back to AO’s file with direction to examine issue afresh; Notes assessee’s submission that it had undertaken

Jul 08, 2015

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