Rulings

May 22,2019

Mumbai ITAT rules that TP-provisions [Chapter X] do not apply to income taxed under Tonnage Taxation Scheme (TTS) under Chapter XII-G of the IT Act, holds that TTS is a

May 21,2019

Delhi HC upholds ITAT order on comparables selection for assessee (BPO service provider’s) data processing and data entry services to AE for AY 2010-11; Rejects Revenue’s contention that ITAT ought

May 21,2019

Kolkata ITAT, in second round of proceedings, rejects TPO’s TNMM as MAM and deletes Rs.90.31cr TP adjustment in case of assessee (engaged in turnkey contracting and sub-contracting for power projects,

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May 24,2019

Delhi ITAT accepts assessee’s internal CUP and deletes the TP-addition made on international transaction of purchase of raw materials for assessee (engaged in manufacture/production of GCLE, a drug intermediate which

May 24,2019

Pune ITAT rules on selection of comparables for assessee providing software development services to AEs for AY 2012-13; Accepts assessee’s plea to exclude 4 comparables namely, Cybermate Infotek Ltd.,Cybercom Datamatics Information

May 24,2019

Pune ITAT rules on comparables selection, use of contemporaneous and multiple year data, turnover filter, working-capital and risk adjustments for assessee engaged in providing Software Development Services (SDS), ITeS and

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ITAT: Holds TP-provisions inapplicable to income covered under Tonnage Tax Scheme

Mumbai ITAT rules that TP-provisions [Chapter X] do not apply to income taxed under Tonnage Taxation Scheme (TTS) under Chapter XII-G of the IT Act, holds that TTS is a

May 22,2019

HC: Dismisses Revenue’s appeal; Confirms rejection of sogo-shosha trader classification & FOB-based benchmarking

Delhi HC dismisses Revenue’s appeal against ITAT-order confirming TP-adjustment deletion for Indian subsidiary of Japanese Sogo Shosha entity in respect of business support services provided to AEs regarding sourcing of

May 20,2019

ITAT: Adopts internal-CUP over TPO's TNMM for benchmarking HO-PE onshore services transaction

Kolkata ITAT, in second round of proceedings, rejects TPO’s TNMM as MAM and deletes Rs.90.31cr TP adjustment in case of assessee (engaged in turnkey contracting and sub-contracting for power projects,

May 21,2019

HC: Confirms Infosys BPO exclusion for BPO-service provider following Agnity India; Distinguishes Chryscapital ruling

Delhi HC upholds ITAT order on comparables selection for assessee (BPO service provider’s) data processing and data entry services to AE for AY 2010-11; Rejects Revenue’s contention that ITAT ought

May 21,2019

HC: Admits Revenue’s appeal against ITAT-order on treatment of foreign-AE as tested party

Delhi HC admits Revenue’s appeal questioning whether ITAT erred in holding that the AE’s transactions could be taken into account for ALP determination as tested party; ITAT had directed TPO

May 20,2019

News

HC: Directs ITAT to readjudicate Vodafone royalty matter without being influenced by interim order

Delhi HC disposes Vodafone India’s writ petition challenging ITAT’s interim order (passed in second round of proceedings pursuant to HC’s

Apr 29,2019

CBDT notifies inter-government agreement with USA for exchange of CbCR

CBDT notifies inter-government agreement with USA for exchange of CbCR.

Apr 29,2019

Tax Experts react to CBDT Committee report on PE Profit Attribution

Tax Experts react to CBDT Committee report on PE Profit Attribution.Comments from some of the Top Tax Experts - 

Apr 25,2019

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