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(TP - Transfer pricing adjustment should be restricted to only value of international transaction pertaining to manufacturing operations: ITAT See 'Breaking News')

DTAA - Referral fees earned by foreign concern for their services carried out abroad, cannot be attributed or held as having been "deemed to have accrued or arisen" to said foreign concern in India: ITAT (See 'Breaking News')

TP - No penalty u/s 271G can be levied for non-furnishing of segmental information, without rendering any finding on segmental break-up submitted by taxpayer: ITAT (See 'Breaking News')

I-T - If no expenditure on payment of upfront fee to Foreign company has been incurred by Indian taxpayer entity, then no deduction can be availed by it while filing I-T return: ITAT (See 'Breaking News')

I-T - Commission paid to agents abroad for procuring export orders overseas, does not amount to FTS and hence does not attracts withholding tax liability u/s 195: ITAT (See 'Breaking News')

CBDT clarifies on treatment of farm-in expenditure of E&P Companies (See 'Bulletin Board')

TP - TPO cannot question quantum of benefit accrued to taxpayer entity, for deciding ALP of Intra group services & royalty payments made to overseas AEs: ITAT (See 'Breaking News')

TP - Company having huge brand value & ownership over intellectual property, are not comparable to captive BPO service providers: ITAT (See 'Breaking News')

DTAA - Subscription fees received by non-resident entity from its Indian customers/subscribers has to be assessed as 'royalty': ITAT (See 'Breaking News')

I-T - Once MAP resolution regarding attribution of profits of PE in India stands agreed between Competent Authorities, then matter regarding presence of PE calls for remand: ITAT (See 'Breaking News')

I-T - Disallowance u/s 40(a)(i) cannot be imposed on royalty payments without verifying if taxpayer has deducted or not deducted TDS at time of payment to non-resident: HC (See 'Breaking News')

BEPS - India notifies MLI as per agreement signed in Paris (See 'MLI' in 'INTL Taxation')

Vanishing Demand makes Recession for Real! Tax Regime also contributes! (See 'THE COB(WEB)' in TIOL)

I-T - No TDS u/s 195 is attracted to payments made overseas, if services were rendered outside India and payment was also received abroad: ITAT (See 'Breaking News')

I-T - Payments made abroad for purchasing software without acquiring any copyright, does amount to royalty and hence does not attract TDS liability: ITAT (See 'Breaking News')

TP - Inability to produce segmental profits due to trade difficulties in diamond industry, does not justify levy of penalty u/s 271G, if there is due compliance of Section 92CA & 92D: ITAT (See 'Breaking News')

TP - Confirmation of ALP adjustment & transfer pricing additions in appellate proceedings by FAA, without resorting to independent application of mind, calls for remand: ITAT (See 'Breaking News')

I-T- Merely because the Department's Non-filers Monitoring System issues a notice to the assessee the Revenue is at liberty to issue notice u/s 147 - NO: HC (See 'Breaking News')

Multilateral Instrument - The clock is ticking!! (See 'TII Special')

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TII BREAKING NEWS

Pune, Aug 20, 2019 By TII News Service

DTAA - Referral fees earned by foreign concern for their services carried out abroad, cannot be attributed or held as having been "deemed to have

Mumbai, Aug 20, 2019 By TII News Service

DTAA - Referral fees earned by foreign concern for their services carried out abroad, cannot be attributed or held as having been "deemed to have

Bengaluru, Aug 20, 2019 By TII News Service

TP - No penalty u/s 271G can be levied for non-furnishing of segmental information, without rendering any finding on segmental break-up submitted by taxpayer: ITAT

New Delhi, Aug 20, 2019 By TII News Service

I-T - If no expenditure on payment of upfront fee to Foreign company has been incurred by Indian taxpayer entity, then no deduction can be

< More News >

TII SPECIAL

Aug 14, 2019

Multilateral Instrument - The clock is ticking!!

By Samir Shah and Hitesha Surana

ON 25 June 2019, India deposited its instrument of ratification for Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS (MLI), along with the list of reservations and notifications.This article discusses the basic concepts of MLI, reason and the mechanism for implementation of MLI and India's position with respect to certain

View Previous Column >>

TII EDIT

Jul 10, 2019

Budget Response to International Tax Issues

By D P Sengupta

Gifts to Non-Residents

IN times of crisis, India used to look to its non-resident Indians to come to its rescue. Even at the time of the opening up of the economy, the tax concessions were first given to non-resident Indians (NRI) and it is thus that we have a chapter

View Previous Column >>

BULLETIN BOARD

New Delhi, Aug 19, 2019
CBDT clarifies on treatment of farm-in expenditure of E&P Companies...

New Delhi, Aug 09, 2019
BEPS - India notifies MLI as per agreement signed in Paris...

New Delhi, Jul 26, 2019
IFSC promotion - CBDT exempts a class of persons from filing return u/s 139(1)...

New Delhi, Jul 18, 2019
Protocol amending India-China DTAA comes into force from June 5, 2019; Articles 5, 7, 11, ...

< More News >

TII BRIEF

Paris, Jul 24, 2019
Asian & Pacific economies see buoyancy of tax revenues ...

Paris, Jul 16, 2019
Joblessness in OECD area goes up 68.7% in Q1 ...

Pairs, Jul 09, 2019
CLIs indicate stabilising growth momentum in OECD area ...

New Delhi, Jul 08, 2019
Anomaly relating to interpretation of 'Accounting year' in case of CbCR, stands clarified...

New Delhi, Jul 06, 2019
Scope of Black Money Act widened with retrospective effect...

More News >>

TII SEARCH

Legal Wrangle | Customs | Episode 110

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