ITAT: Confirms TP adjustment deletion; TPO erred in selecting AE as tested party

ITAT dismisses Revenue's appeal, upholds CIT(A) order deleting TP adjustment for assessee engaged in manufacturing and sale of electrical wiring accessories; Rejects TPO's action of selecting AE of

Jan 19, 2016

ITAT: Revenue must justify grounds for comparable exclusion, CIT(A)’s functional-similarity finding unassailed

ITAT upholds CIT(A)’s inclusion of Himachal Futuristic Communication Ltd (HFCL) as a comparable to assessee availing services from AE for provision of technical services for AY 2005-06; Rejects

Jan 19, 2016

ITAT: Admits additional ground contesting comparable having RPT above accepted limits, remits issue

ITAT allows assessee’s additional ground contesting inclusion of Man Diesel India as a comparable by lower authorities (although included by assessee itself in its TP study) as it

Jan 15, 2016

ITAT: Sets aside DRP’s order passed without considering assessee’s detailed objections/submissions

ITAT sets aside assessment order passed pursuant to DRP directions, as assessee’s detailed objections / submissions were not considered by DRP for AY 2006-07; Notes assessee’s submissions that

Jan 15, 2016

ITAT: Directs AO to use TNMM to benchmark AE-exports, following mechanism under TP-provisions

ITAT remits assessee’s international transaction of exports of pharmaceutical products to AE for AY 2002-03 accepting Revenue’s contention that CIT(A) failed to follow the mechanism laid down in

Jan 13, 2016

ITAT: Excludes 4 functionally dissimilar comparables for contract IT/ITeS provider, follows Pegasystems ruling

ITAT rules on selection of comparables for assessee engaged in providing contract IT and ITeS services to AE for AY 2010-11; Excludes E-infochips Bangalore Ltd and Tata Elxsi

Jan 13, 2016