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BWI AUTOMOTIVE TECHNOLOGIES PVT. LTD. VS DEPUTY COMMISSIONER OF INCOME TAX
DELHI TRIBUNAL, Oct 13, 2021

Factors that would influence the profit margin substantially should be kept in mind while rejecting the comparables.

Subject : Transfer Pricing
Legislation Referred To : Section 92C(2)
In Favour Of : Matter remanded

PRINCIPAL COMMISSIONER OF INCOME TAX VS MCKINSEY KNOWLEDGE CENTRE INDIA (P) LTD.
HIGH COURT OF DELHI, Oct 12, 2021

Under no transfer pricing norm, principle or evaluation of any "benefit" can there be a one-sided adjustment taking into account delayed invoices while at the same time...

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

ARISTA NETWORKS INDIA PRIVATE LIMITED VS DEPUTY COMMISSIONER OF INCOME TAX
BANGALORE TRIBUNAL, Oct 05, 2021

Company having very high turnover cannot be compared to the company having low turnover.

Subject : Transfer Pricing
Legislation Referred To : Section 92CA, 143(3)
In Favour Of : Assessee (Partly)

IKEA SERVICES INDIA PVT. LTD. VS ASSISTANT COMMISSIONER OF INCOME TAX
DELHI TRIBUNAL, Oct 01, 2021

Having determined that (TNMM) to be the most appropriate method, the only rules and norms prescribed in that regard could have been applied to determine whether the...

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

COIM INDIA PRIVATE LIMITED VS DY. COMMISSIONER OF INCOME TAX
DELHI TRIBUNAL, Sep 27, 2021

Bench-marking of the transaction by the assessee by using the combined transaction approach by applying TNMM as against the approach of TPO in bench marking the transaction...

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

TOYOTA BOSHOKU AUTOMOTIVE INDIA PRIVATE LIMITED VS DEPUTY COMMISSIONER OF INCOME TAX
BANGALORE TRIBUNAL, Sep 24, 2021

In terms of Rule 46A(4) of the Rules, the CIT(A) has inherent powers to admit additional evidence to enable him to dispose of the appeal or for any other substantial cause...

Subject : Business expenditure
Legislation Referred To : Section 37
In Favour Of : Assessee (Partly)

EVOLVING SYSTEMS NETWORKS INDIA PVT. LTD. VS DEPUTY COMMISSIONER OF INCOME TAX
BOMBAY TRIBUNAL, Sep 24, 2021

Provision for bad and doubtful debts should be taken as operating expenses while computing profit level indicator of the comparable companies.

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

HYUNDAI MOTOR INDIA LTD. VS ASSISTANT COMMISSIONER OF INCOME TAX
CHENNAI TRIBUNAL, Sep 17, 2021

In absence of mutual agreement or arrangement between two or more AEs for allocation, apportionment or contribution to any cost or expenses for a benefit, service or...

Subject : Transfer pricing adjustment
Legislation Referred To : Section 143(3), 92B
In Favour Of : Assessee (Partly)

TECH MAHINDRA BUSINESS SERVICES LIMITED VS DEPUTY COMMISSIONER OF INCOME TAX
BOMBAY TRIBUNAL, Sep 15, 2021

Functionally different companies cannot be selected as comparables.

Subject : Transfer Pricing
Legislation Referred To : Section 92(2), 10A, 143(3), 144C(5)
In Favour Of : Assessee

DEPUTY COMMISSIONER OF INCOME TAX VS AT KEARNEY LIMITED
DELHI TRIBUNAL, Sep 14, 2021

1. The above two appeals filed by the Revenue are directed against the separate Orders Dated 22.09.2017 of the Ld. CIT(A)-38, New Delhi, relating to the A.Ys. 2009-2010 and...

Legislation Referred To : Section 92CA(3)
In Favour Of : Assessee (partly)