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INTL TAXATION INTL MISC TP FDI LIBRARY VISA BIPA NRI
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TP - Amortization of software expenses and forex loss are required to be excluded, while working out operating profit of assessee from export of goods to its AE: ITAT (See 'Breaking News') TP - DRP cannot reject comparables merely because TPO had no occasion to consider them in TP proceedings, if their functional profile & financial parameters are not disputed: ITAT (See 'Breaking News') DTAA - Profits attributable to Indias operation cannot be assessed as 'business profits' in absence of PE, merely because foreign company had business connection in India: ITAT (See 'Breaking News') I-T - When Protocol to treaty itself provides for automatic application of amended provisions of treaty, even then Revenue can insist on separate notification to be issued by Central Govt about beneficial provisions of treaty - HC (See 'Breaking News') CRS Disclosure - OECD seeks inputs on Model Disclosure Rules ( See 'Brief') TP - Transfer pricing matter deserves re adjudication, if information furnished before TPO is incomplete, since Assessee was not granted opportunity to submit the same: ITAT (See 'Breaking News') TP - No ALP adjustment can be made on protective basis applying the bright line test, in case of transaction of AMP expenses: ITAT (See 'Breaking News') DTAA - There is no obligation to deduct TDS on professional charges paid to Non resident, if such payment did not fall within definition of royalty either under DTAA or I-T Act: ITAT (See 'Breaking News') I-T - Assessee should be allowed to withdraw its appeal in view of MAP resolution as agreed between Competent Authorities of India & Foreign State: ITAT (See 'Breaking News') TP - Disagreement over application of benchmarking method, would not amount to question of law, unless it is established that such application resulted in distorted outcome: HC (See 'Breaking News') TP - Royalty paid by AEs to their parent group company, cannot be treated as capital expenditure: ITAT (See 'Breaking News') DTAA - Global corporate guarantee agreement entered with NRI company for securing loans to AEs, cannot be treated as business profit: ITAT (See 'Breaking News') I-T - Mere failure to record detailed discussion in consequential order, is not sufficient to hold that AO has decided to allow expenditure without verification: ITAT (See 'Breaking News') TP - Rate of interest in case of pending receivables from AEs should be determined by applying LIBOR plus suitable basis point keeping in view credit score of AEs: ITAT (See 'Breaking News') TP - When determination of ALP in appeal effect order did not lead to any TP adjustment, with no effect on income of Assessee, no penalty provisions is applicable in such case: ITAT (See 'Breaking News')
 
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