• i2 Technologies Software (P.) Ltd. Vs CIT (Appeals)

[2017] 83 taxmann.com 143 (Bangalore – Trib.)

Value of ESOP has to be excluded from the amount estimated by the TPO as cost of these benefits received by the assessee from its AE without paying anything.

• Sec 192C – CIT vs. Tata Power Solar Systems Ltd.

[2017] 77 taxmann.com 326 (Madras)

Where for purpose of determining ALP, companies assessee, engaged in generation of solar energy, had mistakenly included two companies engaged in area of wind energy in its list of comparable, assessee would be allowed to withdraw these two comparable from its list on ground of functional difference.

• Sec 92C – Rayban Sun Optics India Ltd. vs CIT

[2017] 84 taxmann.com 24 (Delhi)

International transactions of Import of raw materials and components and export of semi-finished goods, could be benchmarked by applying TNMM and not necessary to adopt CUP method or RPM.

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Please note that the above is a summary of judicial decisions and the same should not consider as an advice. We recommend soliciting the advice of the consultant before taking any action. We shall not be held responsible for any action taken by anyone on the basis of this note before consulting us