Rulings

Mar 22,2019

Mumbai ITAT declines entertaining/admitting Revenue’s additional ground for remitting issue of advertisement and publicity (AMP) expenses to TPO for examination from arm’s length perspective whether some benefit has accrued to

Mar 22,2019

Mumbai ITAT deletes TP-adjustment for assessee engaged in provision of IT enabled services to its AE for AY 2008-09, retains the same set of comparables which were selected by TPO

Mar 19,2019

SC issues notice pursuant to Revenue’s SLP against HC-order upholding ITAT’s quashing of assessment framed in the name of non-existent amalgamating company; Erstwhile entity viz. Suzuki Powertrain India Ltd. amalgamated

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Mar 25,2019

Hyderabad ITAT dismisses assessee’s miscellaneous application seeking rectification of Tribunal order regarding TP-adjustment towards international transaction of software development services for AY 2012-13; Observes that in para 5.2 of the

Mar 25,2019

Chennai ITAT rules in assessee’s favour, quashes draft assessment order passed by AO without meeting the mandatory requirements u/s 144C for AY 2014-15; Notes that along with passing a draft

Mar 25,2019

Ahmedabad ITAT holds that assessee’s issuance of corporate guarantee on behalf of AE, without incurring any specific costs, does not constitute an international transaction for AY 2009-10; Notes that TPO

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SC: Revenue challenges quashing of non-existent entity assessment citing Skylight Hospitality; SC issues notice

SC issues notice pursuant to Revenue’s SLP against HC-order upholding ITAT’s quashing of assessment framed in the name of non-existent amalgamating company; Erstwhile entity viz. Suzuki Powertrain India Ltd. amalgamated

Mar 19,2019

SC: Admits Revenue’s SLP challenging HC’s comparables selection & forex gain/loss treatment

SC admits Revenue’s SLP challenging HC-order in case of S.T. Ericsson India [software developer]; HC had upheld exclusion of 2 comparables [Tata Elxsi Limited and Thirdware Solutions] on grounds of

Mar 19,2019

ITAT: TP-provisions inapplicable to share buy-back; Relies on Topsgrup ruling

Kolkata ITAT deletes TP-adjustment on account of alleged excess amount paid (over and above the FMV) for buy-back of equity shares issued to AEs and notional interest imputed on re-characterisation

Mar 20,2019

ITAT: Revenue’s challenge against AMP-expenses when TP-issues attained finality amounts to re-opening, prohibited u/s 92CA(2C)

Mumbai ITAT declines entertaining/admitting Revenue’s additional ground for remitting issue of advertisement and publicity (AMP) expenses to TPO for examination from arm’s length perspective whether some benefit has accrued to

Mar 22,2019

ITAT: Rejects re-characterisation of outstanding AE-receivable as loan; Deletes TP-addition following Kusum Healthcare

Delhi ITAT rejects TPO’s treatment of outstanding AE-receivables as loan and deletes TP-adjustment of interest of Rs. 2.85 crores thereon, in case of assessee (engaged in telecom sector) for AYs

Mar 20,2019

News

Revenue’s 10+ SLPs challenging HC’s application of Softbrands ratio on TP issues & more!

Revenue files 10+ SLPs before SC challenging Karnataka HC orders on TP-issues like comparables selection, application of filters, grant of

Mar 19,2019

India finalizes Bilateral Competent Authority Agreement for exchange of CbCR with USA

India finalizes Bilateral Competent Authority Arrangement, along with an underlying Inter-Governmental Agreement, for exchange of CbC Reports between India and

Mar 15,2019

Danish SC deletes TP-adjustment on Microsoft Denmark’s marketing activities, holds remuneration at ALP

Danish Supreme Court holds remuneration received by Microsoft Denmark (assessee) for marketing activities in Denmark to be at ALP for

Mar 01,2019

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