HC: Lays down law on interpretation of 60-day time limit for passing TPOs-order u/s 92CA(3A) r.w.s. 153

Expressing concern over Softbrands blanket application, SC directs Revenue to delve into individual case merits

HC: Restores TP-adjustment on AE-loans; Directs addressing ‘question of law’ before determination on facts

• In Favour of Both, Partially
• Citation Number :TS-174-HC-2020(CAL)-TP

Revenue concludes arguments in SAP Labs, reiterates TP-principles cannot be hoodwinked in comparables-selection exercise

SC begins hearing high profile comparables case, Revenue emphasises fallacy of HCs blanket application of Softbrands ratio

SC lists Tops Group case on TP-adjustment w.r.t. outbound share investment for March 27

SC lists SAP Labs matter for March 3; States no adjournment for any reason

HC: Admits PwC’s appeal against ITAT-order including TCS e-Serve as comparable

• In Favour of Both, Partially
• Citation Number :TS-614-HC-2020(CAL)-TP

HC: Admits appeal against aggregation of installation, commissioning/engineering service with manufacturing activity

• In Favour of Both, Partially
• Citation Number :TS-116-HC-2020(BOM)-TP

HC: Admits appeal; ITAT held Sec 92B-amendment treating outstanding AE-receivables as international transaction applicable prospectively

• In Favour of Revenue
• Citation Number :TS-65-HC-2020(BOM)-TP

HC: Admits assessees appeal challenging TP-adjustment on intra-group corporate guarantee, posts matter for hearing

HC: Admits EIHs question of law on interest-adjustment, posts matter for hearing in March

SC to hear SLPs against HC-orders deciding TP-issues following Softbrands, on February 4

SC: Revenue challenges Tops Groups HC-order deleting TP-adjustment w.r.t. outbound share investment applying Vodafone-ratio

HC to hear Qualcomm's appeal against ITAT's remand for analyzing agreement, stays TPO-proceedings

SC adjourns SLPs against HC-orders deciding TP-issues following Softbrands, to Jan. 2020

HC: Admits Revenues appeal against ITAT-order holding AMP-expense not international transaction

HC: Admits Revenues appeal challenging ITATs deletion of AMP-adjustment for Loreal India

Copy of SC order dismissing 70 SLPs connected with Softbrands matter over low tax effect

HC: Admits appeal against ITAT-order confirming TP-provisions applicability to insurance company