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Relief to Louis Vuitton: ITAT Holds Bright Line Test not valid Method for making TPA on Advertisement, Marketing & Promotion [Read Order]

Avinash Kurungot

In a significant relief for luxury retail giant Louis Vuitton India Retail Pvt. Ltd. (LV), the Delhi Bench of the Income Tax Appellate Tribunal...

Bombay HC Quashes Income Tax Reassessment Over Change of Opinion and No Failure to Disclose Facts...

Penalty u/s 271AA cannot be Levied without Identifying Missing Documents: ITAT [Read Order]

Delhi High Court - Transactional Net Margin Method - Arms Length Price - TPO Alternative Method - Taxscan

Delhi HC upholds Transactional Net Margin Method as Appropriate Method for Calculating Arm's Length...

ITAT upholds CIT(A) decision on Sales Commission Payments, Concluding No TDS Liability for Fees for...

ITAT remands Shell Energy India's TP Determination Matter After TPO Mistakes Regasification Payment for Operational Support [Read Order]

The Ahmedabad Bench of Income Tax Appellate Tribunal ( ITAT ) remanded matter concerning the Shell Energy India's Transfer Pricing ( TP ) determination after the Transfer Pricing Officer ( TPO )...

Relief to Samsung: Delhi HC rules Loss from Forex Fluctuation on Trading Items accountable as Operational Loss [Read Order]

The Delhi High Court, in relief to Samsung India held that foreign exchange ( forex ) loss arising from trading activities should be treated as an operational loss and not as a non-operational...

Delhi High Court - Relief to Samsung - Forex Fluctuation - Trading Items - Operational Loss - foreign exchange - taxscan

ITAT deletes Adjustment on Guarantee Fee Payment, Upholds Judicial Consistency [Read Order]

Recently, Income Tax Appellate Tribunal ( ITAT ) Ahmedabad ruled in favour of the appellant in an appeal filed against the order of the Assessment Officer (AO) made under Section 143(3) read with...

Assessment Order made after Expiry of One Month of Receiving Directions from dispute Resolution Panel is Time Barred: ITAT [Read Order]

The Chennai bench of the Income Tax Appellate Tribunal ( ITAT ) recently held that the final assessment order passed after expiry of one month from the end of the month in which the DRP directions...

Delhi HC upholds Calculation at Arm's Length of Reimbursement of AMP Expenses Incurred By Sony India On it's AE [Read Order]

In a significant case, the Delhi High Court upheld the calculation at Arm's Length of Reimbursement of advertising, marketing and promotion expenses (AMP) Expenses Incurred by Sony India on its...

Relief to Tech Mahindra: ITAT directs LIBOR plus 80 Basis points for Interest Rate in determining ALP for Loans borrowed in Foreign Currency [Rad Order]

The Income Tax Appellate Tribunal (ITAT), Mumbai Bench, held that the appropriate LIBOR rate should be applied to determine the Arm's Length Price (ALP) for loans borrowed in foreign currency. The...

Arm's Length Price cannot be Done Except under one of the Methods Prescribed u/s 92C(1)of Income Tax Act: ITAT deletes TP Adjustment based on Adhoc Estimation [Read Order]

The Mumbai Bench of Income Tax Appellate Tribunal (ITAT) has deleted the Transfer Pricing (TP) adjustment based on adhoc estimation basis holding that the Arm’s Length Price could not be done under...