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TP - Necessity of ALP adjustment in case of outstanding receivables from AEs, is yet to be decided on touchstone of 'Notional interest': HC (See 'Breaking News') TP - Companies earning foreign exchange from export of goods on FOB basis, cannot be equated as functionally comparable to pure software developers: ITAT (See 'Breaking News') TP - Negative margins shown by any concern for particular assessment year, will not render the same as persistent loss making concern, and hence uncomparable: ITAT (See 'Breaking News') DTAA - Payment made overseas for outright purchase of drawings & designs simplicitor, without any transfer of technology, will not qualify as FTS: ITAT (See 'Breaking News') I-T - Statute does not prescribes further attribution of profits in hands of PE, once ALP procedure has been complied: SC (See 'Breaking News') TP - Mere fact that transaction of 'royalty' and 'intra-group services' are utilized by Assessee for manufacture of final product, is no basis to determine their combined ALP: ITAT (See 'Breaking News') TP - Applying broad functionality of TNMM method is not sufficient enough to select comparables for a taxpayer: ITAT (See 'Breaking News') I-T - Withholding tax liability should be attached to payment of overseas commission, only after examining the nature of such payment: ITAT (See 'Breaking News') Taxing Digital Economy - 110 countries agree to develop tools by consensus (See 'TII Brief') I-T - Payment made to non resident agents, in respect of services rendered abroad for procuring business, is not chargeable to tax as FTS: HC (See 'Breaking News') I-T - Pending matters in relation to international transaction between two Contracting States, should be disposed of as per MAP resolution agreed between them: HC (See 'Breaking News') TP - Margins from different segments of concerns cannot be compared in absence of their segmental details: ITAT (See 'Breaking News) TP - Turnover filter should not be applied rigorously to exclude functionally comparable companies, without establishing its effect on their profitability: ITAT (See 'Breaking News) DTAA - Taxability of overseas receipts has to be determined as per MAP resolution arrived at by competent authority of Contracting States: ITAT (See 'Breaking News)
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About Us (“TII”), established on April 23, 2010, is a dedicated portal on international taxation. TII was launched in response to the changing landscape of taxation in India. It happens to be the FIRST comprehensive and exhaustive online resource for the taxpayers and also tax authorities looking for well-arranged resource on Transfer Pricing, Double Taxation Tax Treaties, FDI, FEMA, BIPA, NRI and Visa guidelines for various categories of expatriates employed in India by MNEs. 

TII is a sister portal of India’s most prestigious and popular taxation and trade portal (TIOL). In a short time of three years, TII has carved a niche for its quality, speed and authenticity among domestic as well as international users. It has earned the respect and confidence of many global experts of international taxation. It is a highly reliable resource for the various fora of the Indian judiciary. Its citations are frequently used by the courts in their decisions. Its well-researched articles are regularly referred to by the policy makers in India. Its recommendations are generally respected by the Ministry of Finance in India.

TII has a huge subscriber-base cutting across users community ranging from Foreign Taxation Division in the CBDT, Directorate of Transfer Pricing & International Taxation to advocates, law firms, MNEs, domestic companies and research organisations. It has an enviable team of inhouse experts and Consulting Editors who keep an eye on the global trend and keep sensitising the policy makers on the future trends of transforming fiscal world.

Consulting Editor

Mr. D.P. Sengupta: Mr Sengupta, a former member of the IRS, retired as Chief Commissioner of Income Tax after more than 33 years of distinguished service. Before that he had a highly satisfying stint as Joint Secretary in the Tax Policy and Legislation division of the Central Board of Direct Taxes.He also served as Joint Secretary in the Foreign Taxation Division of the Ministry of Finance.He was the Competent Authority for India and represented India in the WP1 of the OECD.He is a well known international taxation expert and spoke at various international tax conferences.

CEO & Managing Editor

Shailendra Kumar, founder and CEO of TIOL started his career with The Indian Express Newspaper in 1990 and then moved to The Economic Times where he worked for more than five years before taking the entrepreneurial route to launch TIOL, an idea based on a business need which he realized as a financial journalist. His vision was to create a knowledge-driven company; which eased the burden on corporations and which acted as a media watchdog for Indian tax and trade policies. He spearheads the business in all of its facets, including regular interactions with various policy makers and administrators, and managing the editorial and news gathering team at TII. He was the recipient of the 2001 Outstanding Media Professional Award presented by the India International Professionals Forum.

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