Rulings

Jul 17,2019

Mumbai ITAT quashes entire assessment proceedings as void & illegal considering that draft assessment order was passed in the name of non-existent amalgamating company for AY 2011-12; Notes that despite

Jul 16,2019

Mumbai ITAT deletes TP-addition on account of various guarantees (performance guarantee, performance bank guarantee and advance payment guarantee) provided by assessee on behalf of its AE (wholly owned subsidiary) for

Jul 15,2019

Pune ITAT allows assessee’s additional ground and quashes the final assessment order passed by the AO sans draft assessment order for AY 2008-09, however, retains TP-adjustment on the issue (of

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Jul 17,2019

Bangalore ITAT rules on selection of comparables for assessee engaged in ITes for AY 2008-09; Dismisses Revenue’s plea and upholds CIT(A)’s decision of excluding 2 comparables, namely, Infosys Technology Ltd.

Jul 17,2019

Delhi ITAT allows assessee’s appeal challenging TP-addition of Rs.25.90 crores and dismisses Revenue’s appeal challenging CIT(A)’s deletion of TP-addition of Rs.32.38 crores on account of international transaction of awarding of

Jul 16,2019

Delhi ITAT remits ALP-determination of assessee’s receipt of guarantee fee from AE for AY 2011-12; Notes that approach adopted by TPO/DRP for ALP-determination was not in consonance with the concept

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HC: Dismisses writ; Concealment penalty imposed on TP-adjustment determined under MAP, not ultra-vires

Karnataka HC upholds constitutional validity of Sec 271(1)(c) in so far as imposing concealment penalty on TP-adjustment determined under MAP proceedings; Notes that pursuant to resolution of TP-issue under MAP, AO

Jul 11,2019

ITAT: Deletes AMP-adjustment for assessee distributor considering recovery by way of subvention income

Mumbai ITAT deletes AMP-adjustment of Rs.4.83cr for assessee (engaged in distribution of cardiovascular products, such as heart valve therapy products, cardiac pulmonary products & RMI products, Critical Care and Vascular

Jul 12,2019

SC: Reserves judgment on validity of HC’s quashing of non-existent entity assessment

SC reserves judgment on validity of Maruti Suzuki India’s HC-order upholding ITAT's quashing of assessment framed in the name of non-existent amalgamating company (Suzuki Powertrain India); HC had, following its

Jul 11,2019

ITAT: Deletes TP-addition on performance guarantee considering assessee’s profit from arrangement, if invoked

Mumbai ITAT deletes TP-addition on account of various guarantees (performance guarantee, performance bank guarantee and advance payment guarantee) provided by assessee on behalf of its AE (wholly owned subsidiary) for

Jul 16,2019

ITAT: Rejects Revenue’s allegation of profits diversion using tax haven in Sun Pharma’s case

Ahmedabad ITAT deletes addition in hands of Sun Pharmaceuticals (assessee) on account of alleged diversion of profits on transfer of technology to a group entity based in USA [CARACO] through

Jul 12,2019

News

SC to hear SLPs against HC-orders deciding TP-issues following Softbrands on August 6

SC lists SLPs (SAP Labs India being the lead case) against HC-orders with respect to comparables selection, application of filters

Jul 15,2019

Analysis of direct tax amendments proposed in Finance Bill, 2019

Finance Bill, 2019 announces scheme for faceless e-assessments, measures to promote digital transactions / payments, MAT relief for companies facing

Jul 05,2019

Finance Bill proposes tweak to secondary adjustment provision, rationalizes ‘accounting year’ definition for CbCR

Finance Bill proposes to give Indian entity suffering primary adjustment an option to pay one time tax of 18% plus

Jul 05,2019

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