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TP - If assessee is debt free company and has recovered remittances within agreed terms, there is no red flag of excessive delay in remittance which gives impression that AE is enjoying credit facility beyond reasonable period: ITAT (See Breaking News)

TP - TPO could not have determined Nil ALP for intra group services under CUP method, without bringing on record any comparable uncontrolled transaction: ITAT (See Breaking News)

INTL - Merely receiving salary in India does not render it taxable if services are rendered abroad; taxation depends on place of employment, not mode of salary payment: ITAT (See Breaking News)

I-T - Hypothetical entries in balance sheet and Profit and Loss can't be considered as resulting in real income/expense of assessee: ITAT (See Breaking News)

TP - If assessee purchases goods from its AE and sell same to customers, without any value addition, such transaction needs to be benchmarked using RPM method: ITAT (See Breaking News)

I-T - Amount which is not actually paid by Indian Branch to France HO, can't be treated as FTS in hands of HO under Article-13 of India France DTAA, and hence, can't be taxed in hands of assessee: ITAT (See Breaking News)

TP - Entity which undertakes R&D activities and own intellectual property in form of technology and brand, cannot be compared with software developer: ITAT (See Breaking News)

DTAA - Capital loss incurred under I-T Act r/w Art 13(5) of India-Ireland DTAA can't be set off against short term capital gain derived from sale of rights of entitlement: ITAT (See Breaking News)

TP - AO must provide opportunity of hearing to assessee before transfering his case to TPO, if there is potential of income arising on determination of ALP of international transaction/ specified domestic transaction: HC (See Breaking News)

TP - Comparable company be dropped, where a prior order recalling the inclusion of this company is final and binding: ITAT (See Breaking News)

TP - If ITAT has rightly decided ground pertaining to upward adjustment of international transaction of payment of guarantee fees to AE in favour of Assessee, no writ interference is warranted: HC (See Breaking News)

I-T- Re-assessment proceedings are invalid where reasons recorded by AO are issued after issuing re-assessment notice: ITAT (See Breaking News)

I-T - Role of remitter banker is simply to follow extant procedure and to deduct Tax at source as prescribed under statute: ITAT (See Breaking News)

I-T - If payroll of assessee is in India during assignment period but entire salary reported in Form No.16 is cross charged to Singapore entity, then AO must examine no.of days assessee had worked in India before deciding its taxability: ITAT (See Breaking News)

I-T - If assessee is not having any PE in India and is covered by India US DTAA and MOA, nature of services rendered by assessee on account of which received remunerations can't be described as FIS: ITAT (See Breaking News)

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TII BREAKING NEWS

New Delhi, Apr 24, 2025 By TII News Service

TP - If assessee is debt free company and has recovered remittances within agreed terms, there is no red flag of excessive delay in remittance

New Delhi, Apr 24, 2025 By TII News Service

TP - TPO could not have determined Nil ALP for intra group services under CUP method, without bringing on record any comparable uncontrolled transaction: ITAT

New Delhi, Apr 23, 2025 By TII News Service

I-T - Hypothetical entries in balance sheet and Profit and Loss can't be considered as resulting in real income/expense of assessee: ITAT

Chennai, Apr 23, 2025 By TII News Service

INTL - Merely receiving salary in India does not render it taxable if services are rendered abroad; taxation depends on place of employment, not mode

< More News >

TII SPECIAL

Jun 24, 2024

A peep into Global Tax Reforms Architecture

By Pratap Singh, Principal CIT

THIS article aims to present an overview of the global tax reforms underway, exploring its challenges, key initiatives, and potential outcomes. It explores the importance of international cooperation under UN/G20/OECD, in addressing tax avoidance and ensuring that businesses contribute their fair share to the societies in which they operate.

View Previous Column >>

TII EDIT

Mar 20, 2025

The Trump Card

By D P Sengupta

IT is always entertaining to watch President Trump's interactions with the Press. He has his pet grievances and airs them repeatedly but he does not shy away from taking questions. The answers may, of course, veer off to something bizarre and different. As is by now well known, President Trump

View Previous Column >>

BULLETIN BOARD

New Delhi, Mar 28, 2025
Order under section 119 of the Income-tax Act, 1961 for waiver on levy of interest under s...

New Delhi, Mar 27, 2025
CBDT amends rules to prescribe new Form 26Q & 27Q...

New Delhi, Mar 25, 2025
CBDT amends rules to expand scope of safe harbour rule ...

New Delhi, Feb 20, 2025
CBDT issues budget circular for TDS u/s 192...

< More News >

TII BRIEF

New Delhi, Mar 31, 2025
CBDT makes record; inks 174 APAs in current fiscal...

New Delhi, Mar 26, 2025
CBDT expands scope of safe harbour rules ...

Paris, Mar 21, 2025
Debt markets in Emerging economies grow to USD 3 trillion in 2024: OECD ...

New Delhi, Mar 17, 2025
CBDT clarifies on application of PPT Provision under DTAAs ...

Paris, Feb 26, 2025
G20 merchandise trade slows down in Q4 of 2024 ...

More News >>

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