Rulings

Apr 11,2019

Delhi HC, in second round of proceedings, dismisses Revenue’s appeal challenging ITAT’s deletion of AMP-adjustment for Sony Mobile (engaged in distribution of mobile handsets in India) for AY 2008-09; Regarding

Apr 11,2019

Bangalore ITAT adjudicates certain grounds pursuant to miscellaneous petition filed by assessee claiming that those grounds were not adjudicated in earlier order; Notes that ITAT earlier had upheld TP-addition of Rs.

Apr 03,2019

Delhi ITAT, in second round of proceedings pursuant to remand by HC, holds that reimbursement received for Advertising, Marketing and Promotion (AMP) functions performed by assessee (manufacturer & distributor of

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Apr 18,2019

Kolkata ITAT accepts selection of foreign AE as tested party for assessee engaged in manufacturing of alumina based refractory and ceramic raw materials for AYs 2012-13 & 2013-14; Observes, upon

Apr 18,2019

Bangalore ITAT dismisses Revenue’s appeal on AMP-adjustment for assessee [engaged in trading in finished, semi-finished ophthalmic lenses, optical meters and processing of semi-finished ophthalmic lenses, etc.] for AY 2009-10; Notes Revenue’s

Apr 18,2019

Chennai ITAT, remits TP-issues back to the AO/TPO for determining the ALP in respect of the international transactions undertaken with its AE’s for AY 2012-13; Considers assessee’s submission that due

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ITAT: Accepts foreign AE as tested-party for IT/ITeS provider; Contract migration cost, not operating item

Mumbai ITAT rules on comparables selection, treatment of AE as tested party, treatment of contract migration cost, TP-adjustments on account of guarantee commission and notional interest for extended credit period

Apr 15,2019

ITAT: Accepts assessee’s aggregation approach for benchmarking royalty; Prefers TNMM over TPO’s CUP-method

Delhi ITAT deletes TP-adjustment w.r.t. international transaction pertaining to payment of royalty and technical know-how (for manufacturing a new product i.e. 18mm Alco Fuel Pump as per specific customer demand)

Apr 15,2019

ITAT: Dismisses Revenue’s appeal challenging DRP’s restriction of AMP-adjustment; Follows earlier -order

Delhi ITAT dismisses Revenue’s appeal, upholds DRP order restricting AMP-adjustment to Rs.21.98cr in case of assessee (leading marketer, distributor and producer of quality branded automotive and industrial products and services)

Apr 15,2019

ITAT: Foreign LLP not “eligible assessee” u/s 144C(15)(b); Quashes draft, final assessment orders

Mumbai ITAT allows assessee’s additional ground, finds that assessee [limited liability partnership incorporated in Germany] cannot be termed as an “eligible assessee” u/s 144C(15)(b) and therefore quashes draft & final

Apr 17,2019

ITAT: Rules on comparable selection for ITES provider; Stresses on functional comparability

Mumbai ITAT rules on comparable selection for assesses engaged in provision of IT enabled back office service for AY 2011-12; Dismissing Revenue’s plea, includes Microland Ltd. (rejecting persistent loss plea)

Apr 17,2019

News

CBDT Committee recommends "three-factor" approach to PE attribution, rejects 'FAR' exclusivity

CBDT Committee recommends far reaching changes to current scheme of attribution of profits to Permanent Establishments; In a 86 pages

Apr 18,2019

HC: Recalls its order in McKinsey case on characterization of R&D service as KPO

Delhi HC allows review petition, recalls its own order in the case of McKinsey India for deciding the matter afresh

Apr 17,2019

Taxsutra Special - Report on "Taxation of Digital Economy in India - The Way Forward" by Vidhi Centre for Legal Policy

The Lehman collapse and the subsequent recession was the first trigger for the G-20 to take a critica re-look at

Apr 12,2019

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