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NEWS FLASH

TP - Resale Price Method for benchamarking purposes is appropriate for assessee-company whose activities are limited to purchasing & reselling products without adding any value & which is consistent with those of a routine distributor: HC (See 'Breaking News')

I-T - Payments made overseas for general support services, for which no technology was made available, cannot be taxed as 'FTS': ITAT (See 'Breaking News')

I-T - If purported reasons that prompted AO to reassess and disallow DAP expenditure incurred on production, only demonstrate change of opinion on part of AO, then same can't form basis of reopening: HC (See 'Breaking News')

INTL - Re-assessment proceedings invalidated where based on erroneous information & where commenced in a mechanical manner & without due application of mind: ITAT (See 'Breaking News')

TP - AO could not have assumed jurisdiction u/s 147 based on audit objections after expiry of four years from relevant A.Y: HC (See 'Breaking News')

INTL - Additions framed u/s 69 are invalid where assessee substantiates nature & source of investment & thus discharges onus of proof: ITAT (See 'Breaking News')

DTAA - Comparable company merits being excluded where it operates with extraordinary margins & diverse business interests, including intangibles in contrast to assessee-company: ITAT (See 'Breaking News')

TP - As is trite law, transfer pricing adjustment has to be done only in respect of international transactions with associated enterprises & not at entity level: ITAT (See 'Breaking News')

DTAA - Payments made by Google India Pvt Ltd. to Google Ireland Limited (GIL) for the Adwords program are not in the nature of royalty or FTS & therefore, cannot be taxed in the hands of assessee: ITAT (See 'Breaking News')

TP - No separate ALP adjustment is required for payment of royalty if TNMM approach has been adopted at entity level: ITAT (See 'Breaking News')

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