INTERNATIONAL TAXATION / TRANSFER
- The Delhi ITAT bench in Aithent Technologies Pvt. Ltd. vs. ITO has held that CUP method will determine ALP of interest-free loan for transfer pricing purposes
- The Delhi High Court in Ranbaxy Laboratories Ltd. vs. CIT has held that AO's self-determination of ALP without referring to TPO is "erroneous & prejudicial to interests of revenue"
- The Delhi High Court in DIT vs. Ericsson AB has held that Profits from offshore supply of equipment & software is not taxable in India u/s 9.
- The Bangalore ITAT bench in Genisys Integrating Systems (India) Pvt. Ltd. vs. Dy. CIT has set out important Principles on scope, data & comparability for determining ALP for the purpose of transfer pricing