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GLOBE GROUND INDIA PVT. LTD. VS DEPUTY COMMISSIONER OF INCOME TAX
DELHI TRIBUNAL, Feb 18, 2019

Function of operating an air cargo complex and the function of carrying on a support services for baggage and passenger handling at the airport are not comparable.

Subject : Transfer Pricing
Legislation Referred To : Section 143(3), 144C
In Favour Of : Assessee

ASSISTANT COMMISSIONER OF INCOME TAX & ANR. VS WOLTERS KLUWER (INDIA) PVT. LTD. & ANR.
DELHI TRIBUNAL, Feb 15, 2019

Functionally different companies cannot be selected as comparables.

Subject : Transfer Pricing
Legislation Referred To : Section 92CA
In Favour Of : Assessee(Partly)

DEPUTY COMMISSIONER OF INCOME TAX VS C-CUBE SOLUTIONS PVT. LTD.
BANGALORE TRIBUNAL, Feb 06, 2019

Functionally different companies cannot be treated as comparables.

Subject : Transfer Pricing
Legislation Referred To : Section 92CA
In Favour Of : Assessee

ASSISTANT COMMISSIONER OF INCOME TAX (LTU) VS GLENMARK PHARMACEUTICALS LTD.
BOMBAY TRIBUNAL, Feb 01, 2019

1. This appeal filed by Revenue is directed against the order of the CIT(A)-56, Mumbai dated 31.12.2015 and it relates to A.Y. 2010-11. 2. The grounds of appeal reads as...

Legislation Referred To : Section 14A, 41(1), 92C, 115JB
In Favour Of : Revenue (Partly)

SIEMENS INDUSTRIES SOFTWARE (INDIA) PVT. LTD. VS DEPUTY COMMISSIONER OF INCOME TAX
DELHI TRIBUNAL, Jan 28, 2019

TPO cannot take a different view from earlier AYs as well as subsequent AYs in respect with an issue without providing supporting findings.

Subject : Transfer Pricing
Legislation Referred To : Section 92C
In Favour Of : Matter Remanded

TATA MOTORS LTD. VS DEPUTY COMMISSIONER OF INCOME TAX
BOMBAY TRIBUNAL, Jan 28, 2019

Irrespective of fact whether debenture issued is convertible or non-convertible, it is in nature of loan and thus, any expenditure incurred in relation to issuance of such...

Subject : Business Expenditure
Legislation Referred To : Section 14A, 36(1), 244A, 43B, 144C
In Favour Of : Assessee(Partly)

TE CONNECTIVITY INDIA PVT. LTD. VS ASSISTANT COMMISSIONER OF INCOME TAX
BANGALORE TRIBUNAL, Jan 25, 2019

1. Appeals No. IT(TP)A 231/Bang/2012 and 311/Bang/2012 are cross appeals filed by the assessee and the revenue directed against the order of the CIT(A)-IV, Bengaluru, in...

Legislation Referred To : Section 92C(2), 142(1), 143(3)
In Favour Of : Assessee(Partly)

NIKON INDIA PVT. LTD. VS DEPUTY COMMISSIONER OF INCOME TAX
DELHI TRIBUNAL, Jan 24, 2019

1. This appeal by the assessee is directed against the order dated 9th October, 2018 passed u/s 143(3) read with section 144C of the IT Act, 1961 for Assessment Year...

Legislation Referred To : Section 92B, 143(3), 144C, 234B
In Favour Of : Assessee(Partly)

WHIRLPOOL OF INDIA LTD. VS DEPUTY COMMISSIONER OF INCOME TAX
DELHI TRIBUNAL, Jan 18, 2019

Since basis on which adjustment has been made being BLT itself has been rejected by High Court in assessee's own case, no further interference can be called for.

Subject : Transfer Pricing
Legislation Referred To : Section 92CA(3), 143(3), 144C
In Favour Of : Matter Remanded

FLOUR DANIEL INDIA PVT. LTD. VS ASSISTANT COMMISSIONER OF INCOME TAX
DELHI TRIBUNAL, Jan 17, 2019

Functionally different companies cannot be selected as comparables.

Subject : Transfer Pricing
Legislation Referred To : Section 92CA(1)
In Favour Of : Assessee

WNS GLOBAL SERVICES PVT. LTD. & ORS. VS INCOME TAX OFFICER & ORS.
BOMBAY TRIBUNAL, Jan 16, 2019

Cost incurred by the assessee which is purely in the nature of reimbursement without any mark-up cannot be treated as part of operating cost.

Subject : Transfer Pricing
Legislation Referred To : Section 10A(9), 40(a)(ia), 92B, 195
In Favour Of : Assessee(Partly)

DEPUTY COMMISSIONER OF INCOME TAX VS VIRTUSA (INDIA) PVT. LTD.
HYDERABAD TRIBUNAL, Jan 11, 2019

Giant company engaged into diversified activities cannot be treated as comparable.

Subject : Transfer Pricing
Legislation Referred To : Section 92CA(3)
In Favour Of : Assessee

AIRPORT RETAIL P. LTD. VS DEPUTY COMMISSIONER OF INCOME TAX
BOMBAY TRIBUNAL, Jan 09, 2019

Only when it is impossible or rather difficult to determine the ALP by applying any of the direct methods like CUP, RPM, CPM, then only as a method of last resort, TNMM...

Subject : Transfer Pricing
Legislation Referred To : Section 40(a)(ia), 194H
In Favour Of : Assessee(Partly)

DRHL INDIA SERVICES P. LTD. VS DEPUTY COMMISSIONER INCOME TAX
BANGALORE TRIBUNAL, Jan 04, 2019

Mere furnishing of details of consignment without evidence of participation of holding company in procuring those businesses would not be sufficient to discharge the burden...

Subject : Transfer Pricing
Legislation Referred To : Section 92
In Favour Of : Revenue

DEPUTY COMMISSIONER OF INCOME TAX VS HINDUJA VENTURES LIMITED
BOMBAY TRIBUNAL, Jan 02, 2019

Net profit margin is to be considered qua the comparable uncontrolled transaction or number of such uncontrolled transactions.

Subject : Transfer Pricing
Legislation Referred To : Section 92C, 10(34), 14A and Rule 8D of 1962 Rules
In Favour Of : Assessee

ASSISTANT COMMISSIONER OF INCOME TAX VS FRESENIUS KABI ONCOLOGY LTD.
DELHI TRIBUNAL, Dec 31, 2018

Providing bank guarantee is an international transaction and the same needs to be benchmarked as per provisions of Section 92(1) of the Act.

Subject : Transfer Pricing
Legislation Referred To : Section 92(1), 92B
In Favour Of : Assessee(Partly)

READERS DIGEST BOOK AND HOME ENTERTAINMENT INDIA (P) LTD. AND ANR. VS DEPTUY COMMISSIONER OF INCOME TAX AND ANR.
DELHI TRIBUNAL, Dec 20, 2018

When components of assessee’s Advertising and Sales promotion and postal expenses are different from what is ordinarily understood as an AMP expenses, same cannot be...

Subject : Transfer Pricing
Legislation Referred To : Section 92CA(3)
In Favour Of : Matter Remanded

COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION) VS PHILIP MORRIS SERVICES INDIA SA
HIGH COURT OF DELHI, Dec 18, 2018

Functionally indifferent companies cannot be selected as good comparable.

Subject : Transfer Pricing
Legislation Referred To : Section 260A
In Favour Of : Assessee

BEAM GLOBAL SPIRITS & WINE (INDIA) PVT. LTD. VS DEPUTY COMMISSIONER OF INCOME TAX
DELHI TRIBUNAL, Dec 11, 2018

Functionally indifferent companies cannot be selected as good comparables.

Subject : Transfer Pricing
Legislation Referred To : Section 92CA(4)
In Favour Of : Assessee (Partly)

TNS INDIA PRIVATE LTD VS ASSISTANT COMMISSIONER OF INCOME TAX
HYDERABAD TRIBUNAL, Nov 28, 2018

Functionally different companies cannot be selected as comparables.

Subject : Transfer Pricing
Legislation Referred To : Section 143(3)
In Favour Of : Assessee (Partly)