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TPO not to Step into the Shoes of Assessee to Decide Prudence of Expenditure: ITAT [Read Order]

The Income Tax Appellate Tribunal( ITAT ), Mumbai Bench, has recently, in an appeal filed before it, held that the TPO shall not step into the shoes...

TPO failed to provide details of Comparables obtained u/s 133(6), restores the issue for providing...

Relief to HP: ITAT allows Working Capital Adjustment Claim [Read Order]

Relief to Motorola: ITAT holds AMP Expenses and Warranty Expenses not separate International...

Determination of ALP for Royalty Payment: Delhi HC dismisses Income Tax Department’s Appeal against...

Remand Proceedings shall be concluded within Period prescribed u/s 153 of Income Tax Act: Madras HC [Read Order]

The Madras High Court has ruled that, the period of limitation under the Sections 153 (2A) or 153 (3) was applicable even for remand proceedings before the Assessing Officer, Transfer Pricing Officer...

Reference to TPO is valid only for SDT exceeds threshold limit of 5 Crore u/s 92BA: ITAT [Read Order]

The Delhi bench of the Income Tax Appellate Tribunal (ITAT) comprising of Shri Pradip Kumar Kedia, AM & Shri Yogesh Kumar us, JM has held that reference to TPO is valid only for SDT...

International Transaction should be benchmarked using Custom Valuation Data: ITAT [Read Order]

The Delhi Bench of the Income Tax Appellate Tribunal ( ITAT ) has held that International transactions should be benchmarked using Custom Valuation Data. The assessee, GP Global Energy Pvt. Ltd....

TPO adopts Wrong Gross Profit Margin of Comparable Company: ITAT deletes Transfer Pricing Adjustment on International Transaction [Read Order]

The Mumbai Bench of Income Tax Appellate Tribunal ( ITAT ) has held that Transfer Pricing Officer (TPO) adopts wrong Gross Profit Margin of comparable company and deletes Transfer pricing adjustment...

Dept cannot claim that Time limits are Not Mandatory: Madras HC asks TPO to Pass Order Determining ALP within 60 Days [Read Order]

A division bench of the Madras High Court, while asking the Transfer Pricing Officer to pass an order determining Arm’s Length Pricing within 60 days and held that the department cannot claim that...

Interest u/s 234C shall be calculated based on 'Returned Income': ITAT [Read Order]

The Income Tax Appellate Tribunal (ITAT), Mumbai bench has held that the amount of interest under section 234C of the Income Tax Act, 1961 shall be calculated on the basis of the “returned income”...

Partial relief to Carraro India: ITAT directs AO for re-determining ALP of international transaction of payment of Royalty [Read Order]

In a partial relief to Carraro India, the Pune Bench of Income Tax Appellate Tribunal (ITAT) directed the Assessing Officer (AO) for re-determining Arm‟s Length Price (ALP) of international...

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