Rulings

Aug 13,2019

SC upholds HC-order holding that TP-adjustment made by AO absent TPO reference (where value of international transaction exceeded Rs.5cr) is contrary to CBDT Instruction No 3/2003 dated 20.05.2003 for AY

Aug 12,2019

Delhi ITAT dismisses Revenue’s appeal, upholds deletion of TP-adjustment on account of interest on FCCDs absent chargeability u/s. 4 r.w. Article 11(1) of India-Cyprus DTAA in case of Cyprus based

Aug 09,2019

Pune ITAT excludes 2 comparables for assessee engaged in providing design engineering services to AE for AY 2013-14 and remits ALP-computation for fresh determination; Observes that TPO included Acropetal Technologies

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Aug 16,2019

Delhi ITAT rules on computation of treatment of forex cost on expat salary for computation of cost base for the purpose of charging to the AE under Master Service Agreement

Aug 16,2019

Pune ITAT rejects Revenue’s stand of adopting domestic PLR for benchmarking interest on loan granted to its German AE for AY 2008-09, relies on assessee’s case for AY 2007-08 wherein

Aug 16,2019

Delhi ITAT remits entire appeal for AY 2014-15 to CIT(A) for fresh decision, including the issue of upward adjustment on account of credit notes issued by assessee to its AEs

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ITAT: Sec.4 chargeability pre-condition for invoking Chapter-X; Deletes TP-adjustment towards hypothetical FCCD interest

Delhi ITAT dismisses Revenue’s appeal, upholds deletion of TP-adjustment on account of interest on FCCDs absent chargeability u/s. 4 r.w. Article 11(1) of India-Cyprus DTAA in case of Cyprus based

Aug 12,2019

SC: TP-adjustment made absent TPO-reference contrary to Instruction 3/2003, but permits remand to AO

SC upholds HC-order holding that TP-adjustment made by AO absent TPO reference (where value of international transaction exceeded Rs.5cr) is contrary to CBDT Instruction No 3/2003 dated 20.05.2003 for AY

Aug 13,2019

ITAT: Holds AMP-adjustment not international transaction for assessee-trader in second round of proceedings

Mumbai ITAT, in the second round of proceedings pursuant to HC remand, deletes AMP-adjustment for assessee (trading in life saving devices) for AY 2009-10; HC had directed ITAT to decide

Aug 13,2019

ITAT: Final assessment order passed without draft-order, invalid; Assessee’s participation in proceedings irrelevant

Pune ITAT admits assessee’s additional ground, sets aside final assessment order passed by AO, absent draft assessment order for AY 2009-10; Notes that AO, on receipt of TPO's order proposing

Aug 13,2019

ITAT: Adopts SBI rate for benchmarking trade receivables; Rules on comparables for IT/ITeS provider

Hyderabad ITAT rules on selection of comparables, benchmarking of interest and working capital adjustment for assessee engaged provision of Software Development Services and ITES for AY 2013-14 & 2014-15; Under

Aug 13,2019

News

Key takeaways from ITRAF’s 2019 conference on ‘International Taxation in the Digital Era’

Key takeaways from ITRAF’s 2019 conference on ‘International Taxation in the Digital Era’

Aug 07,2019

SC adjourns SLPs against HC-orders deciding TP-issues following Softbrands

SC adjourns SLPs (SAP Labs India being the lead case) against HC-orders deciding TP-issues following Softbrands; Matter likely to be

Aug 06,2019

SC: Reserves judgment on validity of HC-order invalidating TP-adjustment absent TPO-reference

SC admits Revenue’s SLP and reserves judgment on validity of HC-order invalidating TP-adjustment absent TPO reference (where value of international

Aug 06,2019

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