Friday , July 20, 2018 |   11:48:04 IST
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NEWS FLASH
 
TP - Treatment of certain expenses as operating revenue, for purpose of ALP determination, need not be decided u/s 260A being fact finding exercise - YES: HC (See 'Breaking News') TP - Outstanding receivables from AEs cannot be re-characterized as 'short term loan', without examining its impact on working capital of Indian taxpayer entity: ITAT (See 'Breaking News') TP - Failure to adopt correct margin of comparables during course of ALP determination, merits recall of matter for limited purpose of rectifying such ommission: ITAT (See 'Breaking News') I-T - Commission paid to agents abroad, for procuring export order overseas, does not attracts withholding tax liability u/s 195: ITAT (See 'Breaking News') I-T - Service tax collection by foreign shipping companies on behalf of Government, does not form part of their gross receipts u/s 44B since having no element of profit: ITAT (See 'Breaking News') TP - No reference can be made to TPO for determination of ALP once re-opening is initiated without AO disposing of assessee's objections to reopening: HC (See 'Breaking News') I-T - Interference with Settlement Commissionís findings is not permitted under Writ jurisdiction without any visible manifest error or non application of mind in such findings: HC (See 'Breaking News') India-Qatar DTAA - Exemption granted to interest derived by govt-owned financial agencies (See Notifications in 'Intl Taxation') I-T - Failure to issue notice u/s 143(2) in re-assessment proceedings prior to finalizing re-assessment order is not condonable u/s 292BB: ITAT (See 'Breaking News') TP - Modifications in selection of comparables based on functional & RPT filter is factual analysis & need not be challenged before writ court u/s 260A: HC (See 'Breaking News') TP - CUP is inappropriate for benchmarking international transaction of import made from AEs, if there are differences in dimensions of import made against AEs & third parties: ITAT (See 'Breaking News') TP - Entities undergoing extraordinary events of merger & amalgamation which hugely affect entire business model are not good comparables: ITAT (See 'Breaking News') I-T - Furnishing revised return to rectify omissions in original return is no basis to presume concealment, warranting penalty: ITAT (See 'Breaking News') GST Law Amendments - Will Council make it more taxpayer-friendly? (See 'Cob(Web)' in 'TIOL') TP - Product dissimilarity between two manufacturing entities makes them uncomparable for benchmarking international transaction: ITAT (See 'Breaking News') TP - Once there exists transaction between two AEs, it ceases to be 'uncontrolled transaction' & so goes out of reckoning under Rule 10B(1)(e)(ii): ITAT (See 'Breaking News') TP - Mere reimbursement of pass through costs incurred by Indian entity on behalf of its overseas AE does not entail any markup without any services being rendered: ITAT (See 'Breaking News') TP - In case of foreign company, AO is required to pass draft assessment order in terms of Sec. 144C, if he proposes to make variation in its returned income: HC (See 'Breaking News') Global Forum releases 7 peer review reports (See 'TII Brief')
 
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TII BREAKING NEWS
 
TP - Treatment of certain expenses as operating revenue, for purpose of ALP determination, need not be decided u/s 260A being fact finding exercise -
TP - Outstanding receivables from AEs cannot be re-characterized as 'short term loan', without examining its impact on working capital of Indian taxpayer entity: ITAT
TP - Failure to adopt correct margin of comparables during course of ALP determination, merits recall of matter for limited purpose of rectifying such ommission:
I-T - Commission paid to agents abroad, for procuring export order overseas, does not attracts withholding tax liability u/s 195: ITAT
< More News >
 
TII SPECIAL Jun 12, 2018
 
Reborn ZBB Can Help Entities Grow Amidst Disruption
By Naresh Minocha

WHY Zero-based budgeting (ZBB) has got a new life in the corporate world? Why the Governments across the world largely remain disinterested in retrying ZBB? And why Governments don't subject colossal tax expenditures/incentives to ZBB? Can re-conceived ZBB be perceived as sustainable growth mantra in the age of unforeseen disruptions?

 
TII EDIT Jun 29, 2018
 
Vodafone and international arbitration
By D P Sengupta

RECENTLY, the Delhi High Court has rendered an important decision [2018-TII-33-HC-DEL-INTL] covering a number of issues involving the controversial Bilateral Investment Protection Agreements (BIPA) that India and other developing countries had entered into for attracting foreign investment.

In the case before the Delhi High Court, initially, a Dutch subsidiary of the

 
BULLETIN BOARD
 
New Delhi, Jul 19, 2018
Exim Bank & LIC receive exemption from interest income pursuant to DTAA between India & Qa...
New Delhi, Jul 16, 2018
CBDT prescribes registration form for Non-resident applicants ...
New Delhi, Jun 27, 2018
POEM - CBDT clarifies on computation of income, treatment of unabsorbed depreciation, set ...
New Delhi, Jun 20, 2018
Amendment in Rule 10CB of Income-tax Rules, 1962 in respect of computation of interest inc...
< More News >
 
TII BRIEF
 
Paris, Jul 17, 2018
Global Forum releases 7 peer review reports...
New Delhi, Jul 14, 2018
Non-resident doing business in India through digital means - CBDT seeks comments on change...
New Delhi, Jul 10, 2018
CLIs indicate easing of growth steam in EU & Canada ...
Paris, Jul 06, 2018
OECD publishes new set of bilateral exchanges relating to CRS...
New Delhi, Jul 04, 2018
CBDT takes APA tally to 223 including 20 bilaterals...
 
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GST 1st Anniversary - A Hardlook (Episode 2) | simply inTAXicating
 
 
 
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