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AMP Adjustment of ₹4.32 Cr Based on Bright Line Test Unsustainable: ITAT Grants Partial Relief to Callaway Golf India [Read Order]

The Income Tax Appellate Tribunal (ITAT) Delhi Bench has provided some relief holding that the Bright Line Test (BLT) cannot be applied for...

Entire Income Tax Assessment Must Conclude within 30 Months where TPO Reference Exists: ITAT [Read...

Additional TP Ground on AE as Tested Party Admissible before ITAT: Bombay HC favours Nivea India...

Final Income Tax Assessment Passed beyond One Month from DRP directions Barred by Limitation: ITAT...

Each Assessment Year is Independent, Earlier Orders cannot be Basis for issuing Certificate u/s 197:...

Annual Income Tax Case Digest: ITAT Decisions 2025 [Part XVI]

This annual round-up analytically summarizes the key Direct Tax-Income Tax rulings of the Income Tax Appellate Tribunal (ITAT) reported on Taxscan.in in 2025 Ad Hoc 10% TP Adjustment on Technical...

ITAT Grants Major Relief to SRF Limited, Deletes Major Additions and Treats CER & TUF Subsidy Receipts as Capital [Read Order]

The DelhiBench of the Income Tax Appellate Tribunal (ITAT), has pronounced a common order in the appeals filed by SRF Limited against assessment orders for AY 2011‑12 and AY 2013‑14. The appeals...

Comparables Functionally Dissimilar, Receivables Subsumed in Working Capital: ITAT Deletes TP Adjustment in AMD India Case [Read Order]

The Bangalore Bench of the Income Tax Appellate Tribunal (ITAT) deleted a ₹19.63 crore adjustment proposed by the Transfer Pricing Officer (TPO) against AMD India Pvt. Ltd., as comparables were...

ITAT Deletes ₹444 Crore TP Adjustment on Netflix India, Rules Company is a Limited-Risk Distributor [Read Order]

The Mumbai Bench of the Income Tax Appellate Tribunal (ITAT) deleted a transfer pricing adjustment of Rs. 444.93 crore made on Netflix Entertainment Services India LLP after holding that the company...

Delhi HC Sets Aside ITAT Order for Lack of Reasoned Findings on Functional Comparability in Transfer Pricing Case [Read Order]

The Delhi High Court has set aside an order passed by the Income Tax Appellate Tribunal (ITAT) for failing to provide adequate reasons while deciding on the functional comparability of entities in ...

Bright Line Test Cannot Be Used by AO to Make AMP Adjustments: Delhi HC [Read Order]

In a recent ruling, the Delhi High Court held that the Assessing Officer cannot use the Bright Line Test (BLT) to make transfer pricing adjustments on Advertisement, Marketing, and Promotion (AMP)...

Turnover and size have Impact on comparability: Karnataka HC Upholds exclusion of Infosys & TCS Citing size & turnover [Read Order]

In a recent case, the Karnataka High Court upheld the exclusion made on Infosysy & TCS while considering the comparable holding that turnover and size have impact on comparability ...