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TP - Profit margin agreed upon in Bilateral APA for specific AEs constitutes reliable benchmark for determining ALP of similar transactions with non-covered AEs: ITAT (See Breaking News) TP - Once closely linked transactions are validly benchmarked under TNMM, segregating one component such as intra-group services for separate benchmarking can lead to impermissible double adjustment: ITAT (See Breaking News) TP - In back-to-back project execution model, CUP is appropriate method for benchmarking, and TNMM cannot be forced merely by treating Indian project office as captive sub-contractor: ITAT (See Breaking News)
 
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Hyderabad, Aug 12, 2026 By TII News Service
TP - Profit margin agreed upon in Bilateral APA for specific AEs constitutes reliable benchmark for determining ALP of similar transactions with ...
Pune, Aug 12, 2026 By TII News Service
TP - Once closely linked transactions are validly benchmarked under TNMM, segregating one component such as intra-group services for separate ben...
New Delhi, Aug 12, 2026 By TII News Service
TP - In back-to-back project execution model, CUP is appropriate method for benchmarking, and TNMM cannot be forced merely by treating Indian pro...
New Delhi, Aug 11, 2026 By TII News Service
I-T - Statutory time limits for completing assessments u/s 153 are mandatory in DRP proceedings : ITAT ...
Mumbai, Aug 11, 2026 By TII News Service
TP - ALP rate of interest on loan advanced to AEs shall be determined based on interest rate charged in country where loan is received: ITAT ...
Mumbai, Aug 10, 2026 By TII News Service
I-T - Pure reimbursement of actual expenses on cost-to-cost basis without any profit element does not constitute taxable income and cannot be cla...
Mumbai, Aug 10, 2026 By TII News Service
I-T - Reimbursement of salary costs for seconded employees on cost-to-cost basis does not constitute FTS if Indian entity acts as economic employ...
New Delhi, Aug 10, 2026 By TII News Service
I-T – Beneficial tax rates on dividends provided under DTAA override domestic Dividend Distribution Tax rates u/s 115-O of Income-tax Act: ITAT...
Mumbai, Aug 07, 2026 By TII News Service
DTAA - A transaction is taxable in India where no income arising from such transaction is taxed in India, no profits is attributed to PE in India...
Mumbai, Aug 07, 2026 By TII News Service
I-T - ESOP expenses quantified under fair value method are allowable deductions u/s 37: ITAT ...
Mumbai, Aug 07, 2026 By TII News Service
I-T - Capital gains from sale of shares in real estate company are taxable only in state of residence if investment is minority holding: ITAT ...
Mumbai, Aug 06, 2026 By TII News Service
I-T - Additional claim for treaty relief u/s 90 cannot be admitted for first time before Tribunal if its determination depends on mandatory factu...
New Delhi, Aug 06, 2026 By TII News Service
TP - Comparables must satisfy filters adopted for benchmarking, including RPT threshold, functional comparability, availability of segmental data...
New Delhi, Aug 06, 2026 By TII News Service
TP - Omission of clause (i) of Sec 92BA by Finance Act, 2017, without any saving clause, renders it retrospectively inoperative from date of its ...
New Delhi, Aug 05, 2026 By TII News Service
I-T - Round-trip voyage constitutes carriage of passengers within meaning of Sec 44B: SC ...
Kolkata, Aug 05, 2026 By TII News Service
I-T - Reassessment notice is invalid if recorded reasons are founded on incorrect facts, especially when AO states that information was received ...
Kolkata, Aug 05, 2026 By TII News Service
INTL - Mere signing or generation of an order does not amount to its issuance & that dispatch is a sine qua non for a valid order: ITAT ...
Mumbai, Aug 05, 2026 By TII News Service
TP - Turnover filter adopted by TPO cannot be applied mechanically to exclude otherwise functionally comparable company if deviation from thresho...
Hyderabad, Aug 04, 2026 By TII News Service
TP - Date of uploading DRP directions on ITBA portal & its electronic communication via email, constitutes date of receipt by AO for computing li...
New Delhi, Aug 04, 2026 By TII News Service
TP - Entities engaged in retail trade and aftermarket service possess fundamentally different functional and market profiles compared to a wholes...
 
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