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DTAA - Project office acting as communication channel to support Non-resident entity's main activity of fabrication & installation of platforms, cannot be construed as PE: HC (See 'Breaking News')

TP - Company engaged in rendering highly technical service cannot be compared to captive service providers engaged in rendering mere support services: ITAT (See 'Breaking News')

TP - Losses suffered by entity in a particular assessment year, will not be construed as persistent losses so as to refer it as unfit for purposes of comparison: ITAT (See 'Breaking News')

Hyderabad Encounter - How Instant can be 'Instant Justice'? See ('The Cob(Web)')

I-T - Profit earned by overseas HO to Indian Branches cannot be taxed in India unless they are attributable to Indian Branches, and hence no adjustment is called for: ITAT (See 'Breaking News')

TP - If impact of receivables on working capital and thereby on its profitability already stands factored, no further adjustment is warranted on basis of outstanding receivables: ITAT (See 'Breaking News')

I-T - Legal findings rendered by Full Bench of High Court after discussing all relevant facts & judgments, cannot be questioned by way of review, on frivolous grounds: HC (See 'Breaking News')

Cabinet nod for Agreement on Social Security between India and Brazil (See 'TII Brief')

TP - Concern which is engaged in diversifying field and whose financial segmental is also not available, is unfit for purposes of comparison: ITAT (See 'Breaking News')

TPO is not permited to impose penalty u/s 271G if on date of non-compliance of notice as required u/s 92D(3), only AO was having such statutory power: ITAT (See 'Breaking News')

TP - Simply because one concern was wrongly not considered by taxpayer as comparable, cannot act as deterrent for claiming same as comparable and be considered for evaluation: ITAT (See 'Breaking News')

I-T - Outstanding demand merits interim stay after compliance of pre deposit, in case of dispute relating to application of amendment to respective provision which will decide scope of tax liaibility: ITAT (See 'Breaking News')

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TII BREAKING NEWS

New Delhi, Dec 13, 2019 By TII News Service

DTAA - Project office acting as communication channel to support Non-resident entity's main activity of fabrication & installation of platforms, cannot be construed as PE:

Mumbai, Dec 13, 2019 By TII News Service

TP - Company engaged in rendering highly technical service cannot be compared to captive service providers engaged in rendering mere support services: ITAT

Kolkata, Dec 13, 2019 By TII News Service

TP - Losses suffered by entity in a particular assessment year, will not be construed as persistent losses so as to refer it as unfit

Nainital, Dec 12, 2019 By TII News Service

I-T - Legal findings rendered by Full Bench of High Court after discussing all relevant facts & judgments, cannot be questioned by way of review,

< More News >

TII SPECIAL

Nov 19, 2019

Global Trade & Economic Growth Lose Speed in RTAs Maze

By Naresh Minocha

INDIA'S decision to not join the Regional Comprehensive Economic Partnership (RCEP) is generating sound and fury. This should lead to a holistic study of the net global benefits, if any, of thickening jungle of regional trade/free trade/preferential trade agreements (RTAs/FTAs/PTAs).

The total number of RTAs signed during 1948-2018 stand at staggering

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TII EDIT

Oct 31, 2019

OECD's unified approach to pillar one - know your [A], [B], [C]

By D P Sengupta

SO we are back to digital economy and sharing of taxing rights again. It all began in 2013 with the OECD launching its Base Erosion and Profit Shifting project with much fanfare. OECD (the club of the rich) put addressing the challenges of digital economy at number one of its priorities and we

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BULLETIN BOARD

New Delhi, Oct 24, 2019
Requests for Exchange of Information from field offices for time barring assessment cases...

New Delhi, Oct 22, 2019
CBDT amends Protocol between India- Morocco ...

New Delhi, Sep 18, 2019
Sharing of tax information received under DTAA - CBDT reiterates no sharing with CBI & oth...

New Delhi, Sep 17, 2019
GAAR - CBDT amends Rule 10UC in relation to application to be made in Form 3CEIA to approv...

< More News >

TII BRIEF

New Delhi, Dec 11, 2019
Cabinet nod for Agreement on Social Security between India and Brazil...

Paris, Dec 05, 2019
Tax revenues have plateaued in advanced economies: OECD ...

Brussels, Dec 03, 2019
WCO to plan more anti-smuggling & AML operations ...

Washington DC, Dec 02, 2019
Mexico eyeing USD 86 Bn tax collections ...

Washington DC, Dec 02, 2019
IMF urges against adopting profit tax policy in Ukraine ...

More News >>

TII SEARCH

Legal Wrangle | Direct Tax | Episode 119

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