ITAT: Quashes reassessment to make royalty TP-adjustment absent ‘reason to believe’ income escapement

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

Sep 19, 2019

ITAT: Excludes functionally dissimilar Bodhtree Consulting, FCS Software; Includes SIP Technologies for software developer

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,

Sep 19, 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

Sep 18, 2019

ITAT: Excludes high-end KPOs for medical transcription service provider; Remits forex-fluctuation treatment issue

Bangalore ITAT rules on selection of comparables, treatment of FOREX gain/loss, benefit of +/- 5% for assessee engaged in providing medical transcription services to its AE for AY

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

Sep 18, 2019

ITAT: Remits TP-issues of royalty payments, ALP-differences in distribution/software development segments; Follows earlier order

Bangalore ITAT remits TP issues, in respect of ALP differences in royalty payments, distribution & software development segments, support services (specified domestic transactions), back to AO for fresh

Sep 17, 2019