![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]")
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...
![Rates for power made available through Indian Energy Exchange are not applicable to consumers; rather, they are rates to DISCOM: ITAT deletes TP Adjustment against Tata Steel [Read Order]](https://www.taxscan.in/wp-content/uploads/2023/11/Tata-Steel-TP-Adjustment-against-Tata-Steel-income-tax-taxscan.jpg "Rates for power made available through Indian Energy Exchange are not applicable to consumers; rather, they are rates to DISCOM: ITAT deletes TP Adjustment against Tata Steel [Read Order]")
![Pass Through Cost directly relatable to Advertisement & Publicity, Business Promotion and participation in trade events are excluded from cost base :ITAT Grants relief to BBC World (India) [Read Order]](https://www.taxscan.in/wp-content/uploads/2023/11/bcc-1.jpg "Pass Through Cost directly relatable to Advertisement & Publicity, Business Promotion and participation in trade events are excluded from cost base :ITAT Grants relief to BBC World (India) [Read Order]")
![ITAT Deletes Secondary Adjustment for Upfront Discount Payment by Tech Mahindra to Secure Software and IT Services Contract with Non-Resident Venture Partner [Read Order]](https://www.taxscan.in/wp-content/uploads/2023/11/ITAT-Secondary-Adjustment-Discount-Payment-Tech-Mahindra-Secure-Software-IT-Services-Contract-Non-Resident-Venture-Partner-taxscan.jpg "ITAT Deletes Secondary Adjustment for Upfront Discount Payment by Tech Mahindra to Secure Software and IT Services Contract with Non-Resident Venture Partner [Read Order]")
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...
![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]](https://www.taxscan.in/wp-content/uploads/2023/11/Tech-Mahindra-ITAT-Directs-LIBOR-plus-80-Points-for-Interest-Rate-ALP-for-Loans-Foreign-Currency-TAXSCAN.jpg "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]")
Existence of International Transaction on account of Receivables: Delhi HC confirms no Upward Adjustment is Required [Read Order]
The Delhi High Court confirmed no upward adjustment is required on the existence of international transaction on account of receivables. By the instant appeal the appellant/assessee sought to...
![Existence of International Transaction on account of Receivables: Delhi HC confirms no Upward Adjustment is Required [Read Order]](https://www.taxscan.in/wp-content/uploads/2023/11/Existence-International-Transaction-account-of-Receivables-Delhi-HC-Upward-Adjustment-TAXSCAN.jpg "Existence of International Transaction on account of Receivables: Delhi HC confirms no Upward Adjustment is Required [Read Order]")
Failure of Comparable as chosen by DRP, then same Loses Comparability for determining ALP: ITAT rules in favour of Tata Chemicals [Read Orer]
In a major relief to M/s. Tata Chemicals Ltd, the Mumbai Bench of the Income Tax Appellate Tribunal (ITAT), ruled that on failure of comparable as chosen by the Dispute Resolution Panel (DRP), then...
![Failure of Comparable as chosen by DRP, then same Loses Comparability for determining ALP: ITAT rules in favour of Tata Chemicals [Read Orer]](https://www.taxscan.in/wp-content/uploads/2023/11/Failure-Comparable-DRP-Loses-Comparability-determining-ALP-ITAT-Tata-Chemicals-TAXSCAN.jpg "Failure of Comparable as chosen by DRP, then same Loses Comparability for determining ALP: ITAT rules in favour of Tata Chemicals [Read Orer]")
Exclusion of OTL Comparable while Benchmarking Engineering, Technical and Inspection Segment which was Accepted by the TPO: Delhi HC directs ITAT to Decide u/s 254
The Delhi High court has directed the Income Tax Appellate Tribunal (ITAT) to decide the issue under Section 254 of Income Tax Act 1961 on exclusion of Onward Technologies Limited (OTL) comparable...
RPM is the most Appropriate Method in International Transactions of Celio Future Fashion pertaining to Import of Men’s Wear for Resale: ITAT directs De novo Benchmarking [Read Order]
The Mumbai Bench of Income Tax Appellate Tribunal (ITAT) has directed denovo benchmarking holding that the Resale Price Method (RPM) is the most appropriate method in international transactions of...
![RPM is the most Appropriate Method in International Transactions of Celio Future Fashion pertaining to Import of Men’s Wear for Resale: ITAT directs De novo Benchmarking [Read Order]](https://www.taxscan.in/wp-content/uploads/2023/10/RPM-most-Appropriate-Method-International-Transactions-Celio-Future-Fashion-pertaining-Import-of-Mens-Wear-Resale-ITAT-Directs-De-novo-Benchmarking-taxscan.jpg "RPM is the most Appropriate Method in International Transactions of Celio Future Fashion pertaining to Import of Men’s Wear for Resale: ITAT directs De novo Benchmarking [Read Order]")
No transfer pricing applicable to income from operation carried out through qualifying ships taxed under TTS: ITAT [Read Order]
The Income Tax Appellate Tribunal (ITAT) Mumbai bench held that no transfer pricing applicable to income from operation carried out through qualifying ships taxed under Tonnage Tax Scheme(TTS). ...
![No transfer pricing applicable to income from operation carried out through qualifying ships taxed under TTS: ITAT [Read Order]](https://www.taxscan.in/wp-content/uploads/2023/10/No-transfer-pricing-applicable-income-operation-carried-qualifying-ships-taxed-under-TTS-ITAT-TAXSCAN.jpg "No transfer pricing applicable to income from operation carried out through qualifying ships taxed under TTS: ITAT [Read Order]")
ITAT deletes TP Adjustment by TPO towards Payment of Royalty on Technology paid to Cadbury Adams USA LLC, and Cadbury Enterprises Pte Ltd [Read Order]
The Mumbai Bench of Income Tax Appellate Tribunal (ITAT) has deleted the Transfer Pricing (TP) adjustment by the Transfer Pricing Officer (TPO) towards the payment of royalty on technology paid to...
![ITAT deletes TP Adjustment by TPO towards Payment of Royalty on Technology paid to Cadbury Adams USA LLC, and Cadbury Enterprises Pte Ltd [Read Order]](https://www.taxscan.in/wp-content/uploads/2023/09/ITAT-TP-Adjustment-by-TPO-towards-Payment-Royalty-on-Technology-paid-to-Cadbury-Adams-USA-LLC-Cadbury-Enterprises-Pte-Ltd.jpg "ITAT deletes TP Adjustment by TPO towards Payment of Royalty on Technology paid to Cadbury Adams USA LLC, and Cadbury Enterprises Pte Ltd [Read Order]")