Digest Of Important Judgements On Transfer Pricing, International Tax And Domestic Tax (Jan To March 2. Shri Sunil Moti Lala, Advocate has prepared a compilation of 5.

International Tax (3. Domestic Tax (1. 55 cases) reported in January to March 2. A PDF copy of the digest is available for download. He has also given the appeal numbers in some cases so as to enable the judgements to be retrieved from the website of the respective Court or Tribunal.

The digest will prove invaluable to all practitioners of taxation law. The Digest comprises of all the important judgements dealing with transfer pricing, international taxes and domestic taxation laws. A brief head note is given for each case. The Digests for the earlier periods are available here I. Transfer Pricing a. International transactions/ Associated Enterprise.

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International transactions 1. The Tribunal, relied on the decision of the co- ordinate bench in the case of the assessee for the earlier year and held that AMP expenditure could not be held to be an international transaction on the basis of probable incidental benefit to the AE absent an agreement for sharing AMP expenditure.

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It held that the Revenue had to show that there existed an agreement or arrangement or understanding between the assessee and its AE whereby the assessee was obliged to spend excessively on AMP in order to promote the brand of the AE in absence of which the impugned transaction could not be considered as an international transaction under section 9. B of the Act. Thomas Cook (India) Ltd v DCIT – TS- 6. ITAT- 2. 01. 7 (Mum) – TP2. The Tribunal, relying on the provisions of section 9. B which provides that even an arrangement, understanding or an action in concert having a bearing on the profit income, losses or assets of the enterprises would qualify as international transaction, held that the sharing of cost between Nike India (assessee) and its AE in respect of contract with BCCI for promotion and brand building of Nike was an international transaction noting that the assessee had incurred the expenditure for the promotion of brand Nike since the agreement between brands in the territory enhanced the brand value of NIKE which belonged to the AE of the assessee.

In respect of other local AMP expenses the tribunal held that such expenditure cannot be regarded as an independent international transaction as there was no agreement or arrangement in writing or otherwise with the AE. Nike India Pvt Ltd – TS- 1. ITAT- 2. 01. 6 (Bang)- TP3. The Court considering assessee’s reliance on Maruti Suzuki HC ruling and other judgments which were not available before TPO, remitted to the file of the TPO the issue relating to existence of international transaction of AMP expenses for fresh consideration. Bacardi India Pvt Ltd- TS- 1. ITAT- 2. 01. 6 (Del)- TP4. The Court relying on the decision in Sony Ericsson Mobile Communications India Pvt.

The Court noting that the LG Electronics . Accordingly, it directed the tribunal to decide whether the reporting of the AMP in regard to the outbound business constituted and international transaction. LE Passage to India Tour & Travels (p) Ltd & ANR – (2. CCH 0. 09 (Del)5. The Tribunal upheld the applicability of provisions of Chapter X on the international transactions entered into by assessee (engaged in production & telecasting of Common Wealth Games 2.

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Bombay High Court decision in Vodafone India Services Private Limited . ACIT – TS- 1. 49- ITAT- 2. DEL)- TP ITA No. 1.

Del/2. 01. 5 dated 1. Associated Enterprise. The Tribunal held that in the case of public sector companies, even if all or majority of the shareholdings are by the union or state governments, these companies for that reason alone cannot be said to be associated enterprises for the purpose of section 9. A. Circular No. 9/7. Ministry of Corporate Affiars clarified that for the purpose of section 3.

Companies Act 2. 01. Companies will not be deemed to be under the same management as the President or the Governor does not hold shares and exercises or controls voting rights as an individual in Govt. The scope of section 3. B), in the Companies Act in force at that point of time, was with respect to the expression . If all public sector undertakings were to be treated as Associated Enterprise, the inter se transactions between all the public sector undertakings would be subject to arm’s length price determination- something which was seemingly quite incongruous and contrary to the scheme of the transfer pricing legislation. Therefore, PSUs cannot be said to be associated enterprises.

Hazira LNG Private Limited – TS- 1. ITAT- 2. 01. 6 (Ahd) – TP7. The Court relying on the decisions in Orchid Pharma and Page Industries, held that assessee (an Indian partnership firm) and the Belgian entity (shares of which were held by partners’ brother and relatives) were not associated enterprises (AEs), as the conditions of section 9. A(2) are not fulfilled. The Court, applying the provisions of section 9.

A(2), held that mere fact of participation of one enterprise in management or control or capital of other enterprise would not make them AEs. While a certain degree of control may actually be exercised by these enterprises over each other, due to relationships of the persons owning these enterprises, that itself was not sufficient to hold the relationship between the two enterprises as .

The Tribunal upheld CIT(A)’s order considering 3 companies namely Multitrade Overseas INC, Harris Freeman & Co. LP and Southern Tea LLC as associate enterprise of the assessee, since all the three companies were being controlled and managed by the same shareholders and persons and therefore the condition provided under section 9. A(2)b, 9. 2A(2)(j) & 9. A(2)(h) were satisfied.

General Commodities Ltd - . The Tribunal upheld the order of the TPO and held that the assessee, engaged in manufacture and selling of generic injectable drugs) had an AE relationship with 2 entities viz. Apotex Corp and Apotex Inc US under section 9. A(2)(i) since 2. 0 percent of the assessee’s sales were to these 2 entities.

Most Appropriate Method. Comparable Uncontrolled Price Method 1.

The Tribunal allowed the appeal of the assessee and upheld the application of CUP as the Most appropriate method for benchmarking the medical transcription services, as against TNMM proposed by the TPO who rejected the CUP method on the ground that the assessee was also involved in development of software for the purpose of medical transcription and therefore the entire activity of the assessee was to be aggregated and benchmarked under TNMM. The Tribunal upheld TNMM over CUP for benchmarking software development services rendered to AEs during AY 2.

IT solutions to several entities in the marketing, Financial Services and Insurance (BFSI) domain) had not provided the total volume of transactions of related parties (both onsite and offshore) for applying CUP method. Further, it held that since assessee’s transactions with Citi Group (used as a comparable in CUP method) fell in the same class although software features may not have been identical, TNMM was more appropriate than CUP. Polaris Consulting & Services Ltd - TS- 2- ITAT- 2.

CHNY)- TP1. 2. Where the assessee had applied CUP method on the basis of the gross margin earned from availing similar services from third parties but the TPO rejected CUP Method on the ground that assessee had failed to justify similarities between services availed from AEs and non- AEs, and applied TNMM on entity level which was upheld by the CIT(A),the Tribunal remitted transfer pricing issues related to benchmarking of freight & forwarding services availed by the assessee from its AEs during AY 2. CIT(A) had not adjudicated issues related to application of most appropriate method (MAM). Will Loesch India Private Limited – TS- 4- ITAT- 2.

ATM, Bank ATM, Bank Branches, ATM Locators, Bank Address. Ground Floor, Kalapurnam, Near Municipal Market, CG Road, Ahmedabad - 3. Phone Number: 0. 79- 4. Branch Timings: 1. Saturdays. Cash Timings: 1.

Saturdays. Branch Working days: This branch will remain closed on Sundays and 2nd & 4th Saturdays. NH 6, Akola - 4. 44 0. Phone Number: 0. 72. Branch Timings: 1.

Saturdays. Cash Timings: 1. Saturdays. Branch Working days: This branch will remain closed on Sundays and 2nd & 4th Saturdays. Bus Stop, Aurangapura, Aurangabad - 4. Phone Number: 0. 24.

Branch Timings: 1. Saturdays. Cash Timings: 1.

Saturdays. Branch Working days: This branch will remain closed on Sundays and 2nd & 4th Saturdays. Road, Bengaluru - 5. Phone Number: 0. 80 - 6. Branch Timings: 1. Saturdays. Cash Timings: 1. Saturdays. Branch Working days: This branch will remain closed on Sundays and 2nd & 4th Saturdays. No. 9. 1, Prestige South End, South End Road, Opposite Surana College, Jayanagar, Bengaluru - 5.

Phone Number: 0. 80- 4. Branch Timings: 1. Saturdays. Cash Timings: 1. Saturdays. Branch Working days: This branch will remain closed on Sundays and 2nd & 4th Saturdays. Alternatively, You can reach our 2.

Citi. Phone Helpline at 1. Please note that telephone calls made to / from Citibank branches may be recorded for quality monitoring purposes. Nagar, Bhopal - 4. Phone Number: 0. 75. Branch Timings: 1.

Saturdays. Cash Timings: 1. Saturdays. Branch Working days: This branch will remain closed on Sundays and 2nd & 4th Saturdays.

Ramaswamy Road, 3rd Street, Abhiramapuram, Alwarpet, Chennai - 6. Phone Number: 0. 44- 4. Branch Timings: 1. Saturdays. Cash Timings: 1. Saturdays. Branch Working days: This branch will remain closed on Sundays and 2nd & 4th Saturdays. Alternatively, You can reach our 2.

Citi. Phone Helpline at 1. Please note that telephone calls made to / from Citibank branches may be recorded for quality monitoring purposes. Road, Begumpet, Secunderabad - 5.

Phone Number: 0. 40- 4. Branch Timings: 1. Saturdays. Cash Timings: 1. Saturdays. Branch Working days: This branch will remain closed on Sundays and 2nd & 4th Saturdays. Apurupa Silpi, Survey No. Gachibowli Village, Serilingampally Mandal, Hyderabad, Ranga Reddy District - 5. Branch contact- Tel: +9.

Branch Timings: 1. Saturdays. Cash Timings: 1. Saturdays. Branch Working days: This branch will remain closed on Sundays and 2nd & 4th Saturdays. Road, Opposite Orbit Mall, Indore, Pincode: 4. Phone Number: 0. 73. Branch Timings: 1. Saturdays. Cash Timings: 1.

Saturdays. Branch Working days: This branch will remain closed on Sundays and 2nd & 4th Saturdays. Hexen For Windows 95 Download Image. Road, Jalandhar - 1. Phone Number: 0. 18. Branch Timings: 1.

Saturdays. Cash Timings: 1. Saturdays. Branch Working days: This branch will remain closed on Sundays and 2nd & 4th Saturdays. Wing A, Lalani Residency, Survey No. Village Kavesar,Opp. Suraj Water Park, Near Waghbil Naka, Ghodbunder Road, Thane (West) - 4. Phone Number: 0. 22- 2. Branch Timings: 1.

Saturdays. Cash Timings: 1. Saturdays. Branch Working days: This branch will remain closed on Sundays and 2nd & 4th Saturdays. Bombay Mutual Building, 2. D. N. Road, Fort, Mumbai - 4. Phone Number: 0. 22- 4.

Branch Timings: 1. Saturdays. Cash Timings: 1. Saturdays. Branch Working days: This branch will remain closed on Sundays and 2nd & 4th Saturdays. Ammu Bungalow, B/1, V. Mehta Road, JVPD Scheme, Juhu, Mumbai - 4. Phone Number: 0. 22- 6. Branch Timings: 1.

Saturdays. Cash Timings: 1. Saturdays. Branch Working days: This branch will remain closed on Sundays and 2nd & 4th Saturdays. Mahatma Phule Bhavan, Palm Beach Road Junction, Sector 1.

Vashi, Navi Mumbai - 4. Phone Number: 0. 22- 6. Branch Timings: 1.

Saturdays. Cash Timings: 1. Saturdays. Branch Working days: This branch will remain closed on Sundays and 2nd & 4th Saturdays. West View Building, Linking Road, Khar (West), Mumbai - 4. Phone Number: 0. 22- 4. Branch Timings: 1.

Saturdays. Cash Timings: 1. Saturdays. Branch Working days: This branch will remain closed on Sundays and 2nd & 4th Saturdays. Times Square IT Park, Wing .

Andheri- Kurla Road, Marol Andheri (E), Mumbai - 4. Phone Number: 0. 22- 6. Branch Timings: 1.

Saturdays. Cash Timings: 1. Saturdays. Branch Working days: This branch will remain closed on Sundays and 2nd & 4th Saturdays. Ground floor, Shop no. G9 & G1. 0, Palladium, Phoenix Mills Compound, 4. Senapati Bapat Marg, Lower Parel, Mumbai - 4. Phone Number: 0. 22- 4. Branch Timings: 1.

Cash Timings: 1. 1am to 6 pm. Command Conquer First Decade Keygen Crack Code there. Branch Working days: Monday to Sunday. Alternatively, You can reach our 2. Citi. Phone Helpline at 1. Please note that telephone calls made to / from Citibank branches may be recorded for quality monitoring purposes.

Vidhan Bhawan, Civil Lines, Nagpur - 4. Door No. 2. 5/4. 27/3, Railway Station Road, Nandyal - 5. Phone Number: 0. 85. Branch Timings: 1.

Saturdays. Cash Timings: 1. Saturdays. Branch Working days: This branch will remain closed on Sundays and 2nd & 4th Saturdays. Bhosala Military School, 5. D'Souza Colony, College Road, Nasik - 4. Phone Number: 0. 25.

Branch Timings: 1. Saturdays. Cash Timings: 1. Saturdays. Branch Working days: This branch will remain closed on Sundays and 2nd & 4th Saturdays. Westin Hotel, North Koregaon Park Main Road, Pune - 4. Phone Number: 0. 20- 6.

Branch Timings: 1. Saturdays. Cash Timings: 1. Saturdays. Branch Working days: This branch will remain closed on Sundays and 2nd & 4th Saturdays. Kakadia Complex, Ghod Dod Road, Surat - 3. Phone Number: 0. 26. Branch Timings: 1.

Race Course Tower, Gotri Road, Vadodara - 3. Phone Number: 0. 26. Branch Timings: 1. Saturdays. Cash Timings: 1.

Saturdays. Branch Working days: This branch will remain closed on Sundays and 2nd & 4th Saturdays.