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12673700Section 92C Transfer pricing Determination of ALP CIT(A) adopted TP analysis made by TPO ... -- Assessee entered into international transaction with its AE. CIT(A), instead of examining the legali......
2021 TaxPub(DT) 1642 (Del-Trib) Intercontinental Hotels Group (India) (P) Ltd. v. Dy. CIT Matter Remanded, Del-Trib, ITA No. 4240/Del/2017, 03-Mar-2021

12552000Section 92B Transfer pricing International transaction AMP expenses Absence of any agreement betwe -- Assessee claimed deduction of AMP expenses incurred by it. TPO treated AMP expenses as excessive and......
2021 TaxPub(DT) 1221 (Pune-Trib) Kimberly Clark Lever (P) Ltd. v. ACIT In favour of Assessee, Pune-Trib, ITA No. 2481/Pun/2012, 22-Feb-2021

12494000Section 92C Transfer pricing Determination of ALP Selection of comparables Functional dissimilaritie -- Assessee rendered software development services to its AE abroad. TPO considered Bodhtree Consulting......
2021 TaxPub(DT) 0910 (Bang-Trib) Triology E-Business Software India (P) Ltd. v. Dy. CIT In favour of Assessee, Bang-Trib, IT(TP)A No. 1851/Bang/2019, 15-Feb-2021

12525900Section 36(1)(iii) Business deduction under Section 36(1)(iii) Interest on borrowed capital Capital -- Assessee claimed deduction under section 36(1)(iii). AO disallowed assessee|s claim proportionately ......
2021 TaxPub(DT) 1069 (Mum-Trib) Agility Logistics (P) Ltd. v. Dy. CIT Matter Remanded, Mum-Trib, ITA No. 7199/Mum/2017, ITA No. 6679/Mum/2018, 11-Feb-2021

12504000Section 92C Transfer pricing Determination of ALP Whether CIT(A) justified in restricting transfer p -- Revenue filed appeal against the order of CIT (A) in restricting the addition made by AO on the basi......
2021 TaxPub(DT) 1010 (Mum-Trib) Dy. CIT v. Sitel India Ltd. In favour of Assessee, Mum-Trib, ITA No. 561/Mum/2011, 09-Feb-2021

12461000Section 92C Transfer pricing Computation of ALP Treatment of foreign exchange gain -- Revenue filed appeal against the order of CIT(A) with regard to the Forex gain earned from Software ......
2021 TaxPub(DT) 0748 (Bang-Trib) Dy. CIT v. Acusis Software India (P) Ltd. Revenue Dismissed, Bang-Trib, IT(TP)A No. 111/Bang/2020 & C.O. No. 8/Bang/2020, 08-Feb-2021

12465700Section 92C Transfer pricing Determination of ALP Tested party vis-a-vis least complex theory -- Assessee entered into transactions with its AE abroad. Tribunal rejected assessee|s approach of cons......
2021 TaxPub(DT) 0795 (Mad-HC) Virtusa Consulting Services (P) Ltd. v. Dy. CIT Matter Remanded, Mad-HC, T.C.A. No. 996 of 2018, 04-Feb-2021

12498500Section 92C Transfer pricing Determination of ALP Comparables and adjustment Treatment of foreign ex -- Assessee rendered IT enabled services to its AE abroad. TPO considered foreign exchange loss as a no......
2021 TaxPub(DT) 0954 (Del-Trib) CPA Global Support Services India (P) Ltd. v. ACIT Del-Trib, ITA No. 1524/Del./2017, 03-Feb-2021

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