ITAT: Deletes interest on delayed AE-receivables; Follows Pegsystems, Kusum Healthcare rulings

Hyderabad ITAT deletes interest adjustment made on assessee’s [engaged in software development services] outstanding AE-receivables for AY 2011-12; TPO observing considerable delay in realization of receivables from its

Jun 14, 2018

ITAT: Rejects TPO’s Nil ALP for management cost allocation; Follows earlier-order

Ahmedabad ITAT rejects TPO/CIT(A)’s Nil ALP-determination in respect of allocation of management fees, being assessee’s share of total common cost incurred by the associate concerns relating to the

Jun 14, 2018

ITAT: Remits comparables’ selection, working capital adjustment, operating margin calculation for assessee manufacturer

Delhi ITAT remits the selection of comparables, working capital adjustment & calculation of operating margin issues for assessee engaged in the business of manufacture and sale of electrical

Jun 13, 2018

ITAT: Deletes royalty adjustment; Follows HC & ITAT ruling in assessee's own case

Delhi ITAT deletes TP-adjustment on royalty paid to AE for AY 2011-12, follows HC and ITAT rulings in assessee's own case; Notes that TPO determined ALP of royalty

Jun 13, 2018

ITAT: Software testing cannot be considered as software development, Relies on safe-harbor rules

Bangalore ITAT rejects assessee’s contention for selection of CPM or CUP method to benchmark its provision of software R&D services for AY 2012-13 following ITAT order for AY2013-14,

Jun 13, 2018

ITAT: Adopts LIBOR+300bps as interest rate ALP for loan to AE; Follows earlier-order

Mumbai ITAT directs adoption of LIBOR+300bps as interest rate ALP in respect of advancement of interest free loans/ extended credit facility by assessee to AE for AY 2007-08;

Jun 13, 2018