ITAT: Upholds Forex gain / loss as operating items; Excludes comparables following precedents

Bangalore ITAT allows assessee's grounds on transfer pricing for AY 2011-12, holds 5 companies engagned in software product development as not comparable to assessee's software development service; Further

Sep 25, 2018

ITAT: Excludes 4 functionally dissimilar comparables for software developer & IT-support provider

Delhi ITAT rules on selection of comparables and treatment of forex fluctuation gain/loss for assessee engaged in provision of software development and IT support services to AE for

Sep 25, 2018

ITAT: Dismisses miscellaneous petition against ITAT order quashing assessment on non-existent entity

Bangalore ITAT dismisses Revenue's miscellaneous petition (MP) for AY 2010-11 against ITAT order quashing assessment passed in the name of amalgamating company which ceased to exist on the

Sep 25, 2018

ITAT: Assessee’s ‘commercial wisdom’ to be considered for intra-group services benchmarking; Remits issue

Delhi ITAT remits ALP-determination of receipt of business support and technical support services and Royalty transactions for assessee (engaged in manufacturing and marketing of exhaust gas recirculation

Sep 25, 2018

ITAT: Deletes TP-adjustment on AMP expenditure, rejects Bright Line Test for ALP-determination

Mumbai ITAT deletes TP adjustment holding that AMP expenditure incurred by assessee would not constitute international transaction, also rejects TPO's application of Bright Line Test (BLT) as no such

Sep 25, 2018

SC: Dismisses Revenue’s SLP; HC quashed AO’s final assessment sans draft order post-remand

SC dismisses Revenue’s SLP against Delhi HC order quashing AO’s final assessment order passed in remand proceedings without draft order, thereby violating section 144C(1) for AY 2008-09; HC

Sep 25, 2018