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TP - Where detailed TP documentation relating to assessee's own Indian transactions as well as international transactions are not given, matter w...
TP - Final assessment order cannot be sustained where it is not preceded by draft assessment order as mandated u/s 144C: ITAT...
I-T - Services rendered by non-resident cannot be held as Fee for technical services and such services are not chargeable in India in hands of no...
I-T - Power conferred by Section 254(2) does not extend beyond rectification of errors apparent on record - Filing of detailed submissions by eit...
TP - ALP of interest on foreign currency loan, is to be determined at US Dollar LIBOR, for the year under consideration since loan given to AE is...
I-T- Since Tribunal in AY 2008-09 has already analysed the CUP method employed by the assessee, it is appropriate to restore issue of determinati...
I-T – Disallowance u/s 40(a)(ia) cannot be made where assessee has not deducted tax at source at higher rate only on account of subsequent retr...
I-T- Companies having different functional activities than that of assessee companies are to be excluded from final list of comparables: ITAT...
I-T – Both high and low turnover are grounds to exclude a company from list of comparable companies in determining ALP: ITAT...
TP - AE itself does not form a comparable since corresponding transactions would be rendered as controlled ones only: ITAT ...
DTAA - TP adjustment settled under UK MAP & TP adjustment settled under USA MAP should be adopted across the board for assessee's international t...
TP - Determination of ALP of payment of royalty has to be benchmarked separately and cannot be aggregated with payment for purchase of raw materi...
TP - Final assessment order rightly quashed where not preceded by draft assessment order: ITAT...
TP - Entire AMP expenses cannot be brought within ambit of 'international transaction', if it was incurred by taxpayer to enhance its sale in Ind...
I-T – Expenditure incurred by assessee on market research merely for maintaining its profit-earning ability is revenue in nature and hence, all...
TP - Functional dissimilarity, related party transactions, high turnover and abnormal profitability trend, renders such entity unfit for comparis...
TP - Brokerage rate charged by taxpayer to its overseas AE for 'DVP' trades merits adjustment, if it meets with arm's length principle: ITAT...
I-T – If bonus/commission for services rendered is not paid to employee on or before due date of filing ITR u/s 139(1), it cannot be allowed as...
I-T- Company having very high turnover exceeding Rs. 200 crore cannot be compared to company whose turnover is only Rs. 56.11 crore: ITAT...
TP - Power of revision u/s 263 cannot be exercised in respect of an order which has been held to be invalid: ITAT...
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