Tuesday , February 21, 2017 |   08:55:39 IST
INTL TAXATION INTL MISC TP FDI LIBRARY VISA BIPA NRI
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NEWS FLASH
 
TP - Interest received on current account balances cannot be considered as income derived from business for computing deduction u/s. 80HHC: ITAT (See 'Breaking News') TP - A company having unique intangibles cannot be selected as a valid comparable for a company engaged in providing captive software development services: ITAT (See 'Breaking News') TP - Whether if outstanding balance of receivables from AE is generated out of intl-transactions, it can be argued that no adjustment could be made towards notional interest or receivables from AE - NO: ITAT (See 'Breaking News') Whether when there has been no benchmarking done in respect of AMP expenses before AO/TPO, in order to determine TP adjustment, it is justifiable for Tribunal to remand such issue - YES: ITAT (See 'Breaking News') TP - AMP expenditure cannot be treated as international transaction when incurred by assessee for its own sales promotion and not obligated under any agreement with its AE: ITAT (See 'Breaking News') IT- Assessee engaged only in providing technical services and not commissioning activities, deduction u/s 44BBB cannot be given, tax to be levied as per DTAA: ITAT (See 'Breaking News') TP - Company providing software development services and selling software products cannot be selected as comparable to company engaged in pure software development services: ITAT (See 'Breaking News') TP - Enterprise cannot be said to be AE where entity is not in position to exercise any dominant influence over assessee: ITAT (See 'Breaking News') IT - Notices issued u/s 143(2) ipso facto are insufficient to attract automatic rejection of application filed u/s 245R(2): SC (See 'Breaking News') Do we have Plan B if GST Network fails? (See 'The Cob(Web)' in TIOL) TP - A company cannot be rejected as comparable merely on the ground that its financials came into public domain on a later date: ITAT (See 'Breaking News')
 
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TII BREAKING NEWS
 
I-T - Para 1 of Article 24 of India Singapore DTAA regarding limitation of relief is inapplicable, when income of singapore based shipping company is
I-T - No addition u/s 68 warranted, when SWIFT messages and audited financial statements of foreign investor company prove investment in assessee company based on
TP - Interest received on current account balances cannot be considered as income derived from business for computing deduction u/s. 80HHC: ITAT
TP - A company having unique intangibles cannot be selected as a valid comparable for a company engaged in providing captive software development services: ITAT
< More News >
 
TII SPECIAL Feb 16, 2017
 
Analyzing Indian Thin Capitalisation Rules
By Yogesh Shah, Aparna Parelkar & Jolly Bajaj

THIN capitalisation refers to hidden equity capitalisation by borrowing higher level of debt as compared to equity and leveraging capital structure, which leads to reducing taxable profits to the extent of interest paid on debt borrowings. Multinational groups strategize their financing arrangements to create tax-efficient mixture of debt and equity in borrowing jurisdiction

 
TII EDIT Jan 23, 2017
 
Complexity of the Multilateral Convention for combating BEPS
By D P Sengupta

TAX treaties now have a long history starting from the year 1899. For most part, however, tax treaties are bilateral in nature. Although there are a few multilateral treaties like the Nordic Convention but these are between groups of homogeneous states. Taxation is intimately connected to the sovereignty of states and each state

 
BULLETIN BOARD
 
New Delhi, Jan 27, 2017
Clarifications on implementation on GAAR provisions under Income Tax Act, 1961 ...
New Delhi, Jan 24, 2017
Guiding Principles for determination of Place of Effective Management (POEM) of a Company...
New Delhi, Jan 13, 2017
Exchange facility to foreign citizens ...
New Delhi, Jan 11, 2017
CBDT notifies India-Cyprus Protocol...
< More News >
 
TII BRIEF
 
Paris, Feb 09, 2017
OECD/EU makes available database on affordable housing...
New Delhi, Feb 07, 2017
CBDT enters into four more APAs ...
New Delhi, Feb 06, 2017
India, Austria sign protocol to amend DTAA for exchange of tax info...
New Delhi, Feb 03, 2017
Govt trying to revise tax treaties to enable CBI to prosecute black money a/c holders...
New Delhi, Feb 02, 2017
WB to provide USD 201 mn for Technical Education Quality Programme...
 
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