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INTL TAXATION INTL MISC TP FDI LIBRARY VISA BIPA NRI
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TP - Resale Price Method is most appropriate for determining ALP of international transaction in nature of purchase of goods from AEs, which are sold as such to related parties: ITAT (See 'Breaking News') TP - Permission to Assessee to raise objections regarding exclusion of certain comparables, will not prolong proceedings before Revenue authorities: ITAT (See 'Breaking News') Global Forum releases compliance ratings for 10 tax jurisdictions (See 'TII Brief') TP - TP study of Assessee cannot be rejected, merely on ground that Assessee had not availed majority of services as mentioned in technical agreement to be provided by AE: ITAT (See 'Breaking News') DTAA - Taxability of interest granted to Non-resident Assessee u/s 244A of I-T Act, is debatable one, and hence cannot be subjected to rectification u/s 244A: ITAT (See 'Breaking News') TP - If AO makes fresh addition or variation in final assessment order, evidently different from Draft order, it tends to violate scheme mandated u/s 144C: HC (See 'Breaking News') Whether when law itself did not mandate production of a tax residency certificate for claiming benefits under DTAA, no fault can be found with assessee - NO: HC (See 'Breaking News') I-T - Deduction u/s 35(2AB) is allowable, if R&D expenses are incurred by way of reimbursement of salary of employees outside India who were in charge of assessee's R&D facilities in India: ITAT (See 'Breaking News') TP - When direct CUP between AE and Indian entity from whom assessee has taken bandwidth network on lease, is available, then ALP has to be computed under CUP: ITAT (See 'Breaking News') I-T - DRP's directions as well as tax evasion petition relating to previous A.Ys, is sufficient to form reasonable belief that corporate guarentee issued for raising funds through Step Up Coupon Bonds, was sham: HC (See 'Breaking News') TP - Non-consideration of judgment of superior court, while adjudicating identical issue, is a mistake apparent from record and hence requires rectification: ITAT (See 'Breaking News') TP - Company rendering high-end knowledge processing services, cannot be compared to captive service provider: ITAT (See 'Breaking News') Paying GST without ITC? - It's unfair! (See 'THE COB(WEB)' in TIOL) SCORES by SEBI (See 'Corp Einsicht' in Tiolcorplaws.com) OECD shares Draft Update 2017 to Model Tax Convention (See 'TII Brief') TP - No penalty can be levied u/s 271BA, when assessee was prevented by sufficient cause in not furnishing report in Form 3CEB as per provisions of Section 92A: ITAT (See 'Breaking News') TP - Assets along with liabilities, is to be adopted for determining fair market value in case of export of machineries by AE, if assets are acquired by way of purchasing shares: ITAT (See 'Breaking News') TP - Income deferred guarantee commission should be spread over the period to which guarantee commission is related and should be assessed proportionately: ITAT (See 'Breaking News')
 
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