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I-T - Issuing a notice u/s 148 to a non-existent, amalgamated entity is void ab initio and a nullity in the eyes of law: ITAT...
I-T - Detailed ratio payments for shared network services involving brand strategy do not constitute royalty if such services represent distribut...
TP - Omission by AO to make formal reference to TPO is a procedural irregularity & not a incurable illegality; does not warrant outright quashing...
TP - Commercial expediency & reasonableness of remuneration be judged from perspective of a businessman; AO cannot apply subjective standard or m...
TP - If TPO rejected entity on ground of persistent losses but assessee furnished evidence to demonstrate that company has made profit in subsequ...
I-T - Broadcasting is neither ‘scientific work' nor does any copyright subsist in such rights, and fee received towards live broadcasting right...
TP - TPO cannot determine ALP at Nil by questioning necessity or benefit of services: ITAT ...
TP - Foreign exchange gains & losses arising from realization of normal export sale proceeds in course of business with associated enterprises, a...
I-T - Rejection of assessee's claim cannot per se justify levy of penalty for under-reporting or misreporting of income: ITAT ...
TP - Assessment order is complete only on being digitally signed - order is barred by limitation where date borne on order or date on which AO co...
TP - Characterization of entity for transfer pricing purposes must be based on detailed FAR analysis: ITAT ...
DTAA - Corporate charges paid for intra-group managerial, administrative, marketing & business support services & not making available any techni...
I-T - Reimbursements of salary for seconded employees made on cost-to-cost basis without income element are not taxable in hands of foreign recip...
TP - In absence of agreement, arrangement, or understanding between assessee & its AE to share or incur AMP expenses for sole benefit of AE, dome...
TP - No notional interest can be imputed on trade receivables if assessee is debt-free entity: ITAT ...
TP - While an APA is not strictly binding on AYs outside its formal coverage, pricing methodology & agreed margins have strong persuasive value, ...
I-T - Regulatory evidence from bank and RBI confirming identity theft and fraudulent account opening overrides any presumptions arising solely fr...
I-T - Expatriate salary for employees working exclusively in India is not head office expenditure u/s 44C: ITAT...
TP - Entity cannot be excluded solely on ground of government ownership without demonstrating that government ownership led to grants, subsidies,...
TP - TPO's approach of comparing inter-unit transfers of semi-finished goods with third-party sales of finished goods, while ignoring variations ...
 
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