ITAT: 5% tolerance range applicable to arm’s length ‘price’, not ‘profitability’; Remits issue

Mumbai ITAT remits international transaction of purchase of automotive parts, directs AO to verify assessee’s claim that ALP is within 5% tolerance range for AY 2011-12; Notes that

Mar 14, 2018

ITAT: Rejects treatment of corporate guarantee as international transaction for AY 2010-11; Follows Reddy-Laboratories

Hyderabad ITAT rejects TPO/DRP’s treatment of corporate guarantee as an international transaction for AY 2010-11; Considers assessee’s submission that Finance Act 2012 amendment [wherein a clarificatory amendment was

Mar 14, 2018

ITAT: Dismisses Volvo India’s appeal on TP-issues in view of MAP-resolution

Bangalore ITAT dismisses Volvo India’s appeal against TP-issues for AY 2007-08 in view of resolution under MAP; Notes that TP-grounds pertained to TP-adjustment in respect of payment of management/marketing

Mar 14, 2018

ITAT: Stays demand for AY 2010-11 & 2011-12 considering prima facie case in favour of assessee

Kolkata ITAT grants stay of demand for AY 2010-11 mainly arising on account of TP-adjustment, for 6 months or disposal of appeal whichever is earlier, notes that assessee

Mar 13, 2018

ITAT: Accepts assessee’s plea to allow working capital adjustment on actuals, remits issue

Bangalore ITAT, pursuant to Tribunal allowing assessee’s miscellaneous petition, rules on computation of working capital adjustment while computing ALP for AY 2011-12; Notes that Tribunal had allowed assessee’s

Mar 13, 2018

ITAT: Considers segmental profitability using man-hour based allocation, notes APA following similar method

Pune ITAT upholds assessee's contention that while determining ALP of software development services rendered to AE, the segmental result for AE-transactions for AY 2010-11 to be compared and

Mar 13, 2018