Rulings

Sep 18,2019

Delhi ITAT [in second round of litigation] rules that Liaison Office (‘LO’) of Hitachi High Technologies’ [assessee-company incorporated in Singapore, engaged in ‘trading’ operations across ASEAN countries in respect of

Sep 13,2019

Pune ITAT dismisses Revenue’s ground, upholds CIT(A) order treating tax return filed by assessee without Form 3CEB as valid for AY 2008-09; States that u/s 139(9), when return of income

Sep 11,2019

Pune ITAT sets-aside assessment order passed by AO as null and void for AY 2012-13, holds DRP exceeded its jurisdiction in restoring the matter to AO/TPO for undertaking a fresh

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Sep 19,2019

Pune ITAT quashes reassessment order (making TP-adjustment on payment of Trademark Licence Fees to the AE) as arbitrary, bad in law and void-ab-initio for AY 2010-11; Notes that AO did

Sep 19,2019

Pune ITAT rules on selection of comparables in assessee’s software development services segment & TP-adjustment in respect of managerial services for AY 2009-10; In software development services segment, ITAT accepts

Sep 18,2019

Bangalore ITAT partly allows assessee’s appeal, applies margin of 17% markup agreed upon under MAP in respect of Denmark-based AE (constituting  95.89% of assessee’s international transactions) to the transactions with

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ITAT: Hitachi Singapore’s LO constitutes PE in India; Directs profit-attribution under TNMM

Delhi ITAT [in second round of litigation] rules that Liaison Office (‘LO’) of Hitachi High Technologies’ [assessee-company incorporated in Singapore, engaged in ‘trading’ operations across ASEAN countries in respect of

Sep 18,2019

HC: Upholds TP-adjustment deletion on corporate guarantee & share application money; Follows earlier-order

Bombay HC upholds ITAT-order determining 0.5% as corporate guarantee ALP and rejecting re-characterization of share application money as loan for AYs 2008-09 and 2009-10; Follows co-ordinate bench ruling in assessee’s

Sep 18,2019

HC: Admits Revenue’s appeal against ITAT order holding AMP-expense incurrence not international transaction

Bombay HC admits Revenue’s appeal against ITAT-order in the case of Heinz India holding that AMP-expenses incurred does not constitute an international transaction for AY 2008-09 absent agreement between assessee and AE for

Sep 17,2019

ITAT: Excludes 5 comparables for captive software developer citing functional dissimilarity, turnover filter failure

Bangalore ITAT rules on comparables selection and depreciation adjustment for assessee rendering software development support services for AY 2009-10; Characterizes assessee as back-office service provider in the process of software

Sep 17,2019

ITAT: Applies MAP-agreed 17% markup for Denmark AE transactions to non-Denmark AE transactions

Bangalore ITAT partly allows assessee’s appeal, applies margin of 17% markup agreed upon under MAP in respect of Denmark-based AE (constituting  95.89% of assessee’s international transactions) to the transactions with

Sep 18,2019

News

Taxsutra Special: Effective Tax Rate of NIFTY 50 companies, G-20 Corporate tax rates & more……

Taxsutra Special: Effective Tax Rate of NIFTY 50 companies, G-20 Corporate tax rates & more……

Sep 20,2019

CBDT: Stresses on maintaining ‘confidentiality’ of information obtained from foreign jurisdictions under EOI process

CBDT cautions Revenue officers against sharing of information received under EOI process of tax treaties for non-tax purposes “without the

Sep 19,2019

Australia issues draft guidelines on Arm's Length Debt Test for thin capitalization

Australian Taxation Office (‘ATO’) issues Draft Practical Compliance Guidelines for applying the arm's length debt test (to establish an entity’s

Sep 19,2019

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