Rulings

Oct 09,2019

Mumbai ITAT rules on selection of MAM to determine ALP of raw material imports by assessee (manufacturing and distributing chemicals) for AY 2010-11 and 2014-15; Regarding assessee’s claim for adoption

Oct 09,2019

Delhi ITAT deletes AMP-adjustment in case of Samsung India (engaged in manufacture and sale of consumer electronics and home appliances) for AYs 2005-06 and 2007-08 to 2011-12 absent demonstration by

Oct 04,2019

SC dismisses Revenue’s SLP against HC order which had confirmed the ITAT’s view on comparable selection for assessee engaged in providing investment sub-advisory services to its AE for AY 2008-09;

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Oct 17,2019

Kolkata ITAT deletes TP-adjustment on the specified domestic transaction of interest paid, confirms CIT(A)’s finding the interest paid by assessee (engaged in development of residential and commercial complex) to its

Oct 16,2019

Cochin ITAT admits and adjudicates on assessee’s additional grounds on comparable selection and working capital adjustment for AY 2013-14, relying on SC ruling in case of National Thermal Power Corporation,

Oct 16,2019

Mumbai ITAT rules on selection of comparables for assessee providing non-binding investment advisory services related support services to its AEs for AY 2011-12; Accepts assessee’s plea and excludes Motilal Oswal

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HC: Declines interfering with ITAT's setting aside of AO's-order passed sans DRP-reference

Madras HC rejects Revenue’s appeal, declines to interfere with ITAT’s order setting aside final assessment passed by AO incorporating TPO’s second order (considering DRP’s directions) without again referring matter to

Oct 14,2019

ITAT: Deletes Sec 271(1)(c)-penalty; HC’s admission of assessee’s appeal renders TP-issue debatable

Delhi ITAT deletes Sec 271(1)(c) penalty levied by the AO/CIT(A) in respect of TP-adjustments for assessee (engaged in manufacturing of auto exhaust catalyst) for AYs 2007-08 and 2008-09; Notes that

Oct 11,2019

ITAT: Remits comparability of 4 companies for software developer; Follows precedents

 Bangalore ITAT rules on selection of comparables for assessee engaged in providing software development services to AE for AY 2013-14; Regarding comparability of Larson & Toubro Infotech sought to be

Oct 11,2019

ITAT: Quashes assessment as time-barred u/s 153(2A) though order passed within time-limit from DRP-directions

Mumbai ITAT, in second round of proceedings, quashes AO’s final assessment order as invalid, being barred by limitation u/s 153(2A) for AYs 2008-09 and 2009-10, upholds TNMM as MAM for

Oct 16,2019

ITAT: Remits selection of foreign-AE as tested-party issue; Directs AO/TO to verify TP-study

Mumbai ITAT remits issue of selection of foreign AE as tested party for assessee (engaged in the business of civil structural, designing and detailing services) for AY 2009-10 to 2014-15; Assessee

Oct 11,2019

News

Taxsutra TP Stay Cases Update: Recent rulings on stay of demand

Taxsutra brings to you a consolidated digest of 10+ recent rulings revolving around stay of demandClick below to view 10+ stay

Oct 17,2019

Copy of SC order dismissing 70 SLPs connected with Softbrands matter over low tax effect

Pursuant to Taxsutra Exclusive sent on September 24, 2019, copy of SC order allowing Revenue to withdraw 70 matters connected to

Oct 03,2019

CBDT amends Rule 10CB relating to interest income computation for secondary adjustments

CBDT amends Rule 10CB relating to computation of interest income pursuant to secondary adjustments; Modifies clause 10CB(1) pertaining to time

Oct 02,2019

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