The Income Tax Appellate Tribunal (ITAT), Mumbai Bench held that PCIT rightly directed the Bank of India’s case to the Transfer Pricing Officer (TPO) under section 92CA for determination of arm’s length price (ALP) in...
In a Relief to Goldman Sachs, the Income Tax Appellate Tribunal (ITAT), Bangalore Bench held that Corporate Social Responsibility (CSR) is also eligible for deduction under Section 80G of Income Tax Act subject to assessee...
The Income Tax Appellate Tribunal (ITAT), Delhi bench has recently deleted an addition against Honda Cars India holding that the provisions of deduction of tax at source (TDS) would not be applicable in case of...
The Income Tax Appellate Tribunal (ITAT) held that exclusion of comparables based on turnover is valid. The facts relating to the transfer pricing issue are that the assessee-company is engaged in the activities in India,...
The New Delhi bench of Income Tax Appellate Tribunal ( ITAT ) while allowing the appeal held that party will not be a comparable if the company is engaged in diversified services and majority of...
A two-Judge Bench of the Delhi High Court in Dabur India Ltd. vs. Pr.Commissioner of Income Tax held that Transfer Pricing adjustment is applicable to overseas subsidiary despite of receiving any royalty. In the instant...
The Delhi High Court recently observed that difference of opinion between Commissioner of Income Tax (CIT) (A) and Transfer Pricing Officer (TPO) cannot be a ground for interference. The division bench comprising of Justice S.Ravindra...
A division bench of the Delhi ITAT, last week held that penalty under section 271(1)(c ) of the Income Tax Act, 1961 cannot be levied if the Arm’s Length Price (ALP) was determined as per...
Upholding an order passed by the Transfer Pricing Officer, the division bench of the ITAT, Bengaluru ruled that international Transactions cannot be clubbed unless the AE provide adequate justification for such clubbing. The assessee-Company, a...
In a recent ruling, the Delhi High Court found that the Transfer Pricing Officer (TPO) cannot go beyond a remand order when such remand was based on a specific finding. The division bench comprising of...
In a recent decision, the division bench of the Gujarat High Court held that the Assessing Officer is liable to issue a Show Cause Notice and a speaking Order before referring a case to the Transfer...
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