![ITAT Favours JCB India: Rejects Arbitrary Royalty Adjustments, Directs TPO to Follow Advance Pricing Agreement Standards [Read Order]](https://www.taxscan.in/wp-content/uploads/2025/04/ITAT-JCB-India-Rejects-Arbitrary-Royalty-Adjustments-Directs-TPO-Advance-Pricing-Agreement-Standards-taxscan.jpg "ITAT Favours JCB India: Rejects Arbitrary Royalty Adjustments, Directs TPO to Follow Advance Pricing Agreement Standards [Read Order]")
ITAT Favours JCB India: Rejects Arbitrary Royalty Adjustments, Directs TPO to Follow Advance Pricing Agreement Standards [Read Order]
The Delhi Bench of the Income Tax Appellate Tribunal (ITAT)set aside an arbitrary transfer pricing adjustment on royalty payments and directed the...
![ITAT upholds TPOs Rejection of RRB Energy Ltd. as Comparable Citing Negative Margins & Functional Differences [Read Order]](https://www.taxscan.in/wp-content/uploads/2025/02/ITAT-ITAT-Chennai-RRB-Energy-Ltd-ITAT-Upholds-TPO-Taxscan-.jpg "ITAT upholds TPOs Rejection of RRB Energy Ltd. as Comparable Citing Negative Margins & Functional Differences [Read Order]")
![Foreign AE as tested party for Trading Segment: ITAT Directs TPO to Reevaluate Arm’s-Length Price [Read Order]](https://www.taxscan.in/wp-content/uploads/2025/02/ITAT-Foreign-AE-TPO-taxscan.jpg "Foreign AE as tested party for Trading Segment: ITAT Directs TPO to Reevaluate Arm’s-Length Price [Read Order]")
![Disallowance of ₹4.49 Crore in Management Service Charges as Excessive: ITAT Allows Payment at Arms Length Using Cost Plus Method [Read Order]](https://www.taxscan.in/wp-content/uploads/2024/12/ITAT-ITAT-ahmedabad-Management-Service-Management-Service-Charges-Taxscan.jpg "Disallowance of ₹4.49 Crore in Management Service Charges as Excessive: ITAT Allows Payment at Arms Length Using Cost Plus Method [Read Order]")
Working Capital Adjustment on Outstanding Trade Receivable has to be Verified While Making ALP Adjustment on Notional Interest:Â ITAT [Read Order]
The Ahmedabad bench of the Income Tax Appellate Tribunal ( ITAT ) while remitting the issue of transfer pricing adjustment regarding interest on overdue trade receivables held that working capital...
![Working Capital Adjustment on Outstanding Trade Receivable has to be Verified While Making ALP Adjustment on Notional Interest:Â ITAT [Read Order]](https://www.taxscan.in/wp-content/uploads/2024/05/ITAT-Working-Capital-Adjustment-ALP-Adjustment-on-Notional-Interest-Arms-Length-Price-Interest-Taxscan.jpg "Working Capital Adjustment on Outstanding Trade Receivable has to be Verified While Making ALP Adjustment on Notional Interest:Â ITAT [Read Order]")
Expat Reimbursement & Royalty amounts to Double Deduction? Delhi HC admits Dept Appeal to Decide [Read Order]
A Division Bench of the Delhi High Court has admitted a department appeal as to whether deletion of additions of expat reimbursements and royalty amounts to double deduction. The following...
ITAT uphold upward adjustment towards guarantee fee in favor of bank with respect of transaction carried out by AE’s [Read Order]
The Ahmedabad bench Income Tax Appellate Tribunal (ITAT) confirmed the upward adjustment made towards the guarantee fee in favor of the bank with respect to transactions carried out by Associate...
![ITAT uphold upward adjustment towards guarantee fee in favor of bank with respect of transaction carried out by AE’s [Read Order]](https://www.taxscan.in/wp-content/uploads/2024/04/ITAT-ITAT-uphold-upward-adjustment-fee-bank-taxscan.jpg "ITAT uphold upward adjustment towards guarantee fee in favor of bank with respect of transaction carried out by AE’s [Read Order]")
Management Service Fees paid to Non Resident AEs eligible for Deduction u/s 37(1) of Income Tax Act: ITAT [Read Order]
The Income Tax Appellate Tribunal ( ITAT ) of Delhi held that management service fees paid to non-resident Associate Enterprises are eligible for deduction under Section 37(1) of the Income Tax Act,...
![Management Service Fees paid to Non Resident AEs eligible for Deduction u/s 37(1) of Income Tax Act: ITAT [Read Order]](https://www.taxscan.in/wp-content/uploads/2024/03/ITAT-ITAT-Delhi-Income-Tax-Fees-Deduction-Management-Service-Fees-taxscan.jpg "Management Service Fees paid to Non Resident AEs eligible for Deduction u/s 37(1) of Income Tax Act: ITAT [Read Order]")
Issue in Calculation of Income Tax Refund: Delhi HC directs to Re Compute Refund Payable [Read Order]
The Delhi High Court directed to recompute the Income Tax refund payable. The period prescribed under Section 153(3) of the Income Tax Act,1961 would thus have to necessarily be computed from the...
![Issue in Calculation of Income Tax Refund: Delhi HC directs to Re Compute Refund Payable [Read Order]](https://www.taxscan.in/wp-content/uploads/2024/02/Delhi-High-Court-Income-Tax-Refund-Income-Tax-taxscan.jpg "Issue in Calculation of Income Tax Refund: Delhi HC directs to Re Compute Refund Payable [Read Order]")
Rejecting TP Analysis without Giving any Specific Reason is invalid, CIT(A) validates TP Report: ITAT upholds Order of CIT(A) [Read Order]
The Mumbai bench of the Income Tax Appellate Tribunal ( ITAT ) upheld the order of the Commissioner of Income Tax (Appeals) which validated the Transfer Pricing ( TP ) report by holding that...
![Rejecting TP Analysis without Giving any Specific Reason is invalid, CIT(A) validates TP Report: ITAT upholds Order of CIT(A) [Read Order]](https://www.taxscan.in/wp-content/uploads/2024/01/T-P-Analysis-CITA-TP-Report-ITAT-ITAT-Upholds-Order-of-CITA-Rejecting-T-P-Analysis-without-Giving-any-Specific-Reason-taxscan.jpg "Rejecting TP Analysis without Giving any Specific Reason is invalid, CIT(A) validates TP Report: ITAT upholds Order of CIT(A) [Read Order]")
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...
![Delhi HC upholds Calculation at Arms Length of Reimbursement of AMP Expenses Incurred By Sony India On its AE [Read Order]](https://www.taxscan.in/wp-content/uploads/2023/12/Delhi-High-Court-Sony-India-AMP-Expenses-Reimbursement-of-AMP-Expenses-advertising-promotion-expenses-Associated-Enterprises-taxscan.jpg "Delhi HC upholds Calculation at Arms Length of Reimbursement of AMP Expenses Incurred By Sony India On its AE [Read Order]")