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OECD unemployment rate hangs at 5% in Dec month (See Brief) I-T - Receipts from provision of flight information/data cannot be characterised as royalty, merely because assessee has applied its accumulated experience in compiling the information: ITAT (See Breaking News) DTAA - As is trite law, Fees for Technical Services, not specifically addressed in a DTAA is to be treated as business income if it relates to the ordinary business activity of the foreign AE: ITAT (See Breaking News) DTAA - Payments made to Thai company for transponder services do not amount to royalty under Article 12 of the India–Thailand DTAA, as assessee neither had possession nor control over satellite or transponders: ITAT (See Breaking News) DTAA - CBDT Instruction No. 1/2018, orders passed in scrutiny cases through e-proceedings must be digitally signed by AO; manual signing of such order is fatal procedural defect - order quashed: ITAT (See Breaking News) DTAA - Sale of software not taxable as royalty, where once core software transaction is not taxable, then related & inseparable services cannot independently be treated as Fees for Technical Services: ITAT (See Breaking News) TP - After omission of clause (i) of section 92BA vide Finance Act, 2017, expenditure transactions covered u/s 40A(2), including interest payments to related parties, ceased to be specified domestic transactions: ITAT (See Breaking News) Real Household income stagnates in G7 area in Q3 (See Brief) OECD inflation stable at 3.7% in Dec month in 2025 (See Brief) TP - Mechanical exclusion of comparables by merely relying on coordinate bench decisions, without undertaking a proper FAR analysis or recording reasons on functional dissimilarity, is unsustainable: ITAT (See Breaking News) I-T - Notice for re-assessment u/s 148 for Assessment Year 2015-16, is invalid and barred by limitation if it was issued on or after April 1, 2021: ITAT (See Breaking News) TP - As per Sec 153(4), where reference u/s 92CA was made to TPO, then time limit stands extended by another 12 months: ITAT (See Breaking News) DTAA - Receipts from bandwidth services cannot be taxed as royalty as per section 9(1)(vi) or Article 12(3) of the India-Singapore DTAA: ITAT (See Breaking News) TP - If company's financials show predominantly software development service income and it satisfies all quantitative filters, denial of inclusion merely because it provides ancillary support services is not justified: ITAT (See Breaking News) TP - ALP for benchmarking electricity transactions should include gross rate charged by State Electricity Authority, which includes mandatory charges such as demand and penal charges: ITAT (See Breaking News) DTAA - Provisions of the DTAA are not triggered by DDT paid by a domestic company u/s 115-O: ITAT (See Breaking News) I-T - Proviso to Sec 149 provides that up to A.Y 2021-22 (period before amendment), period of limitation as prescribed in erstwhile provisions of Section 149(1)(b) would be applicable: ITAT (See Breaking News) I-T - Income from distribution of standardized software products by distributor, who does not own intellectual property, cannot be characterized as FTS: ITAT (See Breaking News) I-T - If international transactions between parties relating to non-exclusive distributorship and sale of software, were found to be at arm's length, no further attribution of profit can be made to PE: ITAT (See Breaking News) INTL - Interest paid u/s 201(1A) for delayed deposit of TDS is not compensatory in nature & does not qualify as allowable business expenditure u/s 37(1): ITAT (See Breaking News) INTL - Disallowance u/s 40(a)(i) sustainable where assessee paid a substantial sum to an international consultant, thereby creating an employer-employee relationship attracting TDS u/s 192: ITAT (See Breaking News) I-T - Procedure u/s 144C(1) has to be followed by Assessing Officer only if he proposes to make any variation which is prejudicial to interest of eligible assessee: ITAT (See Breaking News)
 
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