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Search Results For: Saktijit Dey (JM)

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DATE: October 22, 2014 (Date of pronouncement)
DATE: October 26, 2014 (Date of publication)
AY: 2007-08
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CITATION:
In view of the finding of the service-tax authorities that services were rendered, argument that amount paid is a reimbursement of actual cost without profit element is not acceptable and it is chargeable as “fee for included services”

Having held that the amount in question was remitted by the assessee company to ATI Technologies, Canada for certain benefits received by it in the form of services procured by ATI Technologies, Canada from Soctronics India Private Limited and provided …

AMD Research & Development Center vs. DCIT (ITAT Hyderabad) Read More »

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DATE: October 15, 2014 (Date of pronouncement)
DATE: October 20, 2014 (Date of publication)
AY: 2008-09
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CITATION:
Fraud in determination of LIBOR/ EURIBOR no reason to discard it as ALP

The department claimed that in determining the ALP of an international transaction of loan by the assessee to its AE, LIBOR could not be treated as the ALP as there was a “fraud” regarding fixation of ‘LIBOR’ as evidenced by …

Vijay Electricals Limited vs. ACIT (ITAT Hyderabad) Read More »

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DATE: September 19, 2014 (Date of pronouncement)
DATE: October 4, 2014 (Date of publication)
AY: 2008-09
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CITATION:
Operating Profit to operating Revenue should be taken as the PLI and not Operating Profit to Operating Cost

The purpose of identifying the PLI is to ensure that the comparability of the controlled transactions is objective and reference in this regard was made by him to the OECD Transfer Pricing Guidelines 2010, wherein it was explained that the …

DCIT vs. St. Jude Medical India Pvt. Ltd (ITAT Hyderabad) Read More »

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DATE: September 24, 2014 (Date of pronouncement)
DATE: October 4, 2014 (Date of publication)
AY: 2008-09
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CITATION:
No transfer merely because development agreement is entered into

As can be seen from the observations made by CIT(A), he has given specific finding of fact that development agreement has not been acted upon by the developer till date. Therefore, he has concluded that as there is no willingness …

ACIT vs. P. Venkateswara Rao (ITAT Hyderabad) Read More »