Rulings

Apr 11,2019

Delhi HC, in second round of proceedings, dismisses Revenue’s appeal challenging ITAT’s deletion of AMP-adjustment for Sony Mobile (engaged in distribution of mobile handsets in India) for AY 2008-09; Regarding

Apr 11,2019

Bangalore ITAT adjudicates certain grounds pursuant to miscellaneous petition filed by assessee claiming that those grounds were not adjudicated in earlier order; Notes that ITAT earlier had upheld TP-addition of Rs.

Apr 03,2019

Delhi ITAT, in second round of proceedings pursuant to remand by HC, holds that reimbursement received for Advertising, Marketing and Promotion (AMP) functions performed by assessee (manufacturer & distributor of

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Apr 18,2019

Kolkata ITAT accepts selection of foreign AE as tested party for assessee engaged in manufacturing of alumina based refractory and ceramic raw materials for AYs 2012-13 & 2013-14; Observes, upon

Apr 18,2019

Bangalore ITAT dismisses Revenue’s appeal on AMP-adjustment for assessee [engaged in trading in finished, semi-finished ophthalmic lenses, optical meters and processing of semi-finished ophthalmic lenses, etc.] for AY 2009-10; Notes Revenue’s

Apr 18,2019

Chennai ITAT, remits TP-issues back to the AO/TPO for determining the ALP in respect of the international transactions undertaken with its AE’s for AY 2012-13; Considers assessee’s submission that due

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ITAT: Grants deduction for management fees paid to AE; Service availment established

Pune ITAT rejects disallowance of management fee paid by assessee (engaged in ITES business) to its AE for AY 2010-11; Firstly, addresses issue of benefit test applied by TPO, holding

Apr 12,2019

ITAT: Accepts foreign AE as tested-party for IT/ITeS provider; Contract migration cost, not operating item

Mumbai ITAT rules on comparables selection, treatment of AE as tested party, treatment of contract migration cost, TP-adjustments on account of guarantee commission and notional interest for extended credit period

Apr 15,2019

ITAT: Holds export incentive as operating income; Directs inclusion if pertaining to CY turnover

Bangalore ITAT accepts assessee's contention that export incentives are to be considered as part of operating profits, but directs AO/TPO to verify if export incentive pertained to current year's turnover

Apr 12,2019

ITAT: Deletes Rs.300+cr intra-group services TP-adjustment, remits interest adjustment on AE-loan following precedent

Delhi ITAT deletes TP-adjustment of Rs.306cr in respect of intra-group services [MSU charges, reimbursement of expenses, payroll expenses, information technology and other charges] received by assessee [non-resident company engaged in

Apr 12,2019

ITAT: Remits comparables selection, working capital & risk adjustments; Follows precedents

Bangalore ITAT rules on comparables selection, grant of risk & working capital adjustments for assessee for AY 2013-14; Remits comparability of 3 companies [Infosys BPO Ltd, Harltron Communications and Capgemini Business

Apr 12,2019

News

CBDT Committee submits report on profit attribution to PE

CBDT Committee, formed to examine the current scheme of attribution of profits to Permanent Establishment (PE) under Article 7 of

Apr 18,2019

HC: Recalls its order in McKinsey case on characterization of R&D service as KPO

Delhi HC allows review petition, recalls its own order in the case of McKinsey India for deciding the matter afresh

Apr 17,2019

Taxsutra Special - Report on "Taxation of Digital Economy in India - The Way Forward" by Vidhi Centre for Legal Policy

The Lehman collapse and the subsequent recession was the first trigger for the G-20 to take a critica re-look at

Apr 12,2019

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