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

Kavi Priya

The Mumbai Bench of the Income Tax Appellate Tribunal (ITAT) deleted a transfer pricing adjustment of Rs. 444.93 crore made on Netflix Entertainment...

Delhi HC Sets Aside ITAT Order for Lack of Reasoned Findings on Functional Comparability in Transfer...

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

Turnover and size have Impact on comparability: Karnataka HC Upholds exclusion of Infosys & TCS...

ITAT Holds SBI PLR Applicable for Arm’s Length Interest on INR-Denominated FCCDs [Read Order]

ITAT Allows Use of Extrapolated Data for Comparables With Different Year-End in ITeS Transfer Pricing Dispute Involving Goldman Sachs [Read Order]

The Mumbai Bench of Income Tax Appellate Tribunal ( ITAT ) allowed the use of extrapolated data for comparables with a different financial year-end in an ITeS transfer pricing dispute involving ...

Relief for Rolls Royce: ITAT Quashes Time-Barred Assessment Order Passed Beyond S.144C(13) Deadline [Read Order]

The Delhi Bench of Income Tax Appellate Tribunal ( ITAT ) granted relief to Rolls Royce India Pvt. by quashing the final assessment order passed beyond the prescribed time limit under Section...

ALP recomputed by TPO is Invalid as Assesee Followed Prescribed method (TNMM) u/s 92C of Income Tax Act : ITAT allows appeal of Schaeffler India Ltd [Read Order]

In a recent case, the Ahmedabad bench of the Income Tax Appellate Tribunal (ITAT) allowed the appeal of Schaeffler India Ltd. on finding that ALP recomputed by TPO is Invalid as the assessee...

ITAT Allows KBS Creations’ Appeal, Rules No Transfer Pricing Adjustment Without Proved ‘Arrangement’ Under Section 80IA(10) [Read Order]

The Mumbai Bench of the Income Tax Appellate Tribunal (ITAT) has set aside a transfer pricing (TP) adjustment of Rs. 10.98 crore and ruled that the Assessing Officer (AO) failed to establish an...

ITAT Holds Corporate Guarantee as International Transaction, Grants Relief to Tega Industries by Restricting TP Adjustment to 0.5% Fee

The Kolkata Bench of Income Tax Appellate Tribunal (ITAT ) granted relief to Tega Industries by restricting the Transfer Pricing (TP) adjustment to 0.5% in respect of a corporate guarantee fee,...

Bombay HC Dismisses Revenue’s Appeal, Upholds ITAT Order Quashing ‘Mechanical’ Reassessment Initiated Without AO’s Independent Satisfaction [Read Order]

The Bombay High Court has dismissed an appeal filed by the Principal Commissioner of Income Tax-1, Thane, challenging the Income Tax Appellate Tribunal’s ( ITAT ) order quashing reassessment...

Bombay HC Quashes Income Tax Reassessment Over Change of Opinion and No Failure to Disclose Facts [Read Order]

The High Court of Bombay, quashed an income tax reassessment proceedings initiated against the assessee for Assessment Year(AY) 2014–15, holding that the reopening was based on a mere change of...