![Ingersoll Rand (India) Ltd Vs DCIT [IT(TP)A
2005-06
ITAT (Bengaluru Bench) upheld the adjustment
proposed notional interest on outstanding
charging interest from non AEs in case
Fresenius Kabi India Pvt Ltd Vs DCIT [ITA No
ITAT (Pune Bench) upheld that RPM
activities are in relation to trading/distribution
made to the product, even when selling
Assessee.
Important judgments on Transfer pricing
[IT(TP)A. Nos 6 & 7/Bang/2014] – AY 2003 -04 & AY
adjustment made by Revenue wherein Revenue
outstanding receivables from AE since Assessee is
case of delay in receipt of payment.
No.235/PUN/2013] – AY 2008-09
RPM is the most appropriate method where
trading/distribution function and no value addition is
selling and marketing expenses are borne by the
Important judgments on Transfer pricing (25.08.2017)](https://image.slidesharecdn.com/august2017-170825092100/85/August-2017-1-320.jpg)
![ACIT Vs Akzo Nobel Car Refinishes India Pvt
05
ITAT (Delhi Bench) upheld Resale Price Method
benchmarking of international transaction
has not made any value addition to
functions is essential for comparability under
cannot be compromised even under TNMM
Teradata India Pvt. Ltd. Vs ACIT [ ITA No. 87/Del/2017]
ITAT (Delhi Bench) relied upon Kusum healthcare Pvt Ltd and ruled that working
capital adjustment takes into account the cost of Receivables from AE and no
separate adjustment is warranted.
Important judgments on Transfer pricing (18.08.2017)
Pvt Ltd [ITA No. 4096/Del/2011] – AY 2004-
Method is the most appropriate method for
transaction of purchase of goods where Assessee
goods. ITAT ruled that comparability of
under TNMM also and functional similarity
TNMM.
India Pvt. Ltd. Vs ACIT [ ITA No. 87/Del/2017] – AY 2012-13
healthcare Pvt Ltd and ruled that working
capital adjustment takes into account the cost of Receivables from AE and no
Important judgments on Transfer pricing (18.08.2017)](data:image/gif;base64,R0lGODlhAQABAIAAAAAAAP///yH5BAEAAAAALAAAAAABAAEAAAIBRAA7)
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ITAT upholds RPM for distribution functions
- 1. Ingersoll Rand (India) Ltd Vs DCIT [IT(TP)A 2005-06 ITAT (Bengaluru Bench) upheld the adjustment proposed notional interest on outstanding charging interest from non AEs in case Fresenius Kabi India Pvt Ltd Vs DCIT [ITA No ITAT (Pune Bench) upheld that RPM activities are in relation to trading/distribution made to the product, even when selling Assessee. Important judgments on Transfer pricing [IT(TP)A. Nos 6 & 7/Bang/2014] – AY 2003 -04 & AY adjustment made by Revenue wherein Revenue outstanding receivables from AE since Assessee is case of delay in receipt of payment. No.235/PUN/2013] – AY 2008-09 RPM is the most appropriate method where trading/distribution function and no value addition is selling and marketing expenses are borne by the Important judgments on Transfer pricing (25.08.2017)
- 2. ACIT Vs Akzo Nobel Car Refinishes India Pvt 05 ITAT (Delhi Bench) upheld Resale Price Method benchmarking of international transaction has not made any value addition to functions is essential for comparability under cannot be compromised even under TNMM Teradata India Pvt. Ltd. Vs ACIT [ ITA No. 87/Del/2017] ITAT (Delhi Bench) relied upon Kusum healthcare Pvt Ltd and ruled that working capital adjustment takes into account the cost of Receivables from AE and no separate adjustment is warranted. Important judgments on Transfer pricing (18.08.2017) Pvt Ltd [ITA No. 4096/Del/2011] – AY 2004- Method is the most appropriate method for transaction of purchase of goods where Assessee goods. ITAT ruled that comparability of under TNMM also and functional similarity TNMM. India Pvt. Ltd. Vs ACIT [ ITA No. 87/Del/2017] – AY 2012-13 healthcare Pvt Ltd and ruled that working capital adjustment takes into account the cost of Receivables from AE and no Important judgments on Transfer pricing (18.08.2017)