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NEWS FLASH
 
TP - If no adjustment can be made in respect of transaction with unrelated parties u/s 92, then DRP should call for required details, rather than adjudicating on non-AE transactions: ITAT (See 'Breaking News') TP - New proviso to Sec 40A is saving clause by virtue of which, any specified transaction on or before April 01, has to be tested as per provisions of Sec 92C: ITAT (See 'Breaking News') Global Economy in COVID-induced coma - India needs to clear 'political fog' & take bold decisions (See 'taxindiaonline.com') DTAA - Payment made by resident distributors to foreign suppliers for purchase of shrinkwrapped software, does not amount to royalty: ITAT (See 'Breaking News') I-T - Contradictions due to complex web of arrangements involving large number of entities in several jurisdictions in fragmented manner, cannot be put against bonafides of tax demands at stage of stay: ITAT (See 'Breaking News') TP - Power of reassessment of AO for collecting evidences or informations from TPO cannot be crippled down by wrongly interpreting Section 92CA(2B) or (2C): HC (See 'Breaking News') Tax collections in Asia hit by pre-COVID recession: OECD (See 'TII BREIF') Pure software developer is not comparable to software product company having huge intangible asset & brand value: ITAT (See 'Breaking News') DTAA - Project office of foreign company which merely acts as 'communication channel' without any authority to conclude contract, cannot be termed as 'PE': ITAT (See 'Breaking News') Simply because appeal by Revenue is revived at instance of assessee because of its proceedings in HC, that would by no stretch of imagination make such appeal before ITAT, an appeal by assessee u/s 253 of I-T Act: HC (See 'Breaking News') HANDLING OF SEIZED GOODS UNDER THE CUSTOMS ACT, 1962 (See TOG 'THE INSIGHT') TP - Captive service provider cannot be selected as comparable in absence of segmental information and huge functional difference: ITAT (See 'Breaking News') TP - Entity which has committed fraud, as per findings of SEBI regulations, cannot be considered as good comparable for captive service provider: ITAT (See 'Breaking News')
 
 
 
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TII BREAKING NEWS
 
TP - New proviso to Sec 40A is saving clause by virtue of which, any specified transaction on or before April 01, has to be
TP - If no adjustment can be made in respect of transaction with unrelated parties u/s 92, then DRP should call for required details, rather
DTAA - Payment made by resident distributors to foreign suppliers for purchase of shrinkwrapped software, does not amount to royalty: ITAT
I-T - Contradictions due to complex web of arrangements involving large number of entities in several jurisdictions in fragmented manner, cannot be put against bonafides
< More News >
 
TII SPECIAL Jul 13, 2021
 
OECD's Double Standards on Race To Bottom on Direct & Indirect taxes
By Naresh Minocha

IT is time to straighten out the idiom –"Heads I win; tails you lose". This expression should now be reworded as: Head I win; tails I win too in the global taxation arena. The trigger for this forthright message is the Group of seven rich countries (G7's) latest success to

 
TII EDIT Jun 30, 2021
 
SC software case- Copyright and Royalty
By D P Sengupta

THE cases dealt with by the SC were all involving DTAAs with some country or the other. As per the Court's order, in all 18 tax treaties were involved. All the treaties had an Article dealing with Royalty. Essentially, such articles give India a right to tax royalties on a gross

 
BULLETIN BOARD
 
New Delhi, Jul 02, 2021
Guidelines under section 9B and sub-section (4) of section 45 of the Income-tax Act, 1961...
New Delhi, Jul 02, 2021
CBDT amends rule 8AA to tax income of specified entity as capital gains & prescribes Form ...
New Delhi, Jun 04, 2021
RBI issues Circular on Payment of margins for transactions in Government Securities by...
New Delhi, May 17, 2021
Pension Fund Indo-Infra Inc gets Sec 10(23FE) benefits ...
< More News >
 
TII BRIEF
 
Paris, Jul 21, 2021
Tax collections in Asia hit by pre-COVID recession: OECD ...
Paris, Jul 07, 2021
Keep jobs in nucleus of economic recovery to avoid scars in society: OECD...
Paris, Jul 02, 2021
Global Min Tax of 15% - 130 agree; 9 including Ireland disagree ...
Paris, Jun 30, 2021
Policy tools needed to overcome structural frailties of corporate Secor: OECD ...
Geneva, Jun 24, 2021
WTO Ministerial Conference 12 - Members press to resolve appellate body impasse...
 
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