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INTL TAXATION INTL MISC TP FDI LIBRARY VISA BIPA NRI
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TP - Without considering full factual aspect of services involved in international transaction, TP adjustment cannot be proposed: ITAT (See 'Breaking News') I-T - TDS on remittance paid to foreign tax resident not having a PE in India does not fall in hand of tax resident of India: ITAT (See 'Breaking News') I-T Variation u/s 144 beyond scope of DRP, donot rise questions with respect to assessee's beneficial ownership of royalty under India-Cyprus DTAA: ITAT (See 'Breaking News') GST - Sec 50 Imbroglio - CBIC, GSTN & Taxpayers - All three to be blamed! (See 'THE COB(WEB)' in TIOL) EU puts Cayman Islands on tax haven blacklist TP - Assessment order passed in respect of international transactions, without referring matter to TPO as per Section 92CA, is unsustainable: ITAT (See 'Breaking News') I-T - Remand ordered by ITAT solely to examine whether or not assessee has PE in India, is not tenable, where it could have looked into such issue on its own: HC (See 'Breaking News') TP - Harbour Rules u/s 92CB for software development services restricted to lower turnover cap in absence of change in business model: ITAT (See 'Breaking News') TP - ALP needs to be determined for long credit period on trade receivables as international transaction: ITAT (See 'Breaking News') Volume of corporate debt goes up to USD 13.5 tr but quality dips: OECD Study (See 'Brief') TP - Rate of Royalty paid for a Trademark shall be governed by similar rate adopted by assessee in prior period: ITAT (See 'Breaking News') TP - ALP adjustment u/s 92CA(3) cannot claim deductions u/s 10A or 10B: ITAT (See 'Breaking News') IMF's fiscal ideas for Japan February 14, 2020 (See 'Brief') TP - Disallowance on fees for technical services can be governed by prior orders passed in the assessee's own case: ITAT (See 'Breaking News') I-T - Provisions of DTAA shall prevail on conflict with section 206AA of the IT Act: ITAT (See 'Breaking News') I-T - Upon converting company to LLP, tranferring equity shares to partnership qualifies as transfer u/s 2(47) of I-T Act: AAR (See 'Breaking News') Concessional corporate tax rate for domestic companies - CBDT notifies new FORMs 10-IC & 10-ID for exercising option (See 'Bulletin Board') Overhaul of global tax rules to adversely impact Ireland's tax receipts: OECD (See 'Brief')
 
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TP - Without considering full factual aspect of services involved in international transaction, TP adjustment cannot be proposed: ITAT ...
I-T - TDS on remittance paid to foreign tax resident not having a PE in India does not fall in hand of tax resident of India: ITAT ...
I-T Variation u/s 144 beyond scope of DRP, donot rise questions with respect to assessee's beneficial ownership of royalty under India-Cyprus DTA...
TP - Draft assessment order cannot be treated as final order, simply by issuing a corrigendum - such draft order is of no consequence: ITAT ...
I-T -Remanded ordered merely to examine whether or not assessee had PE in India, is tenable, where ITAT could itself have looked into such issue:...
TP - Harbour Rules u/s 92CB for software development services restricted to lower turnover cap in absence of change in business model: ITAT ...
TP - ALP needs to be determined for long credit period on trade receivables as international transaction: ITAT ...
TP - ALP adjustment u/s 92CA(3) cannot claim deductions u/s 10A or 10B: ITAT ...
TP - Rate of Royalty paid for a Trademark shall be governed by similar rate adopted by assessee in prior period: ITAT...
TP - Disallowance on fees for technical services can be governed by prior orders passed in the assessee's own case: ITAT...
I-T - Provisions of DTAA shall prevail on conflict with section 206AA of the IT Act: ITAT ...
I-T - Upon converting company to LLP, tranferring equity shares to partnership qualifies as transfer u/s 2(47) of I-T Act: AAR...
I-T - Failure on part of assessee to access material evidence relied upon by revenue for demand of TDS deduction invalidates such demand: ITAT ...
TP - TPO to compute margin for transactions with non-Australian entities: ITAT ...
TP - TP adjustment warrants being made in respect of an amount which an Indian company incurs on behalf of its AE & which former is unable to rec...
I-T - Penalty merits being imposed, considering that issue of taxability in India of profits earned by foreign branch, is debatable: ITAT ...
I-T - Dismissal of application by AAR does not warrant writ court's intervention, if relevant documents were not submitted before former authorit...
I-T - Assessee cannot be worse off from tax liability from its source jurisdiction when service PE is triggered by foreign services in India: ITA...
TP - No addition of notional interest on receivables towards TP arises when assessee is a debt free company: ITAT ...
TP - Demonstration of refrigeration segment with transport segment must be supported by evidence: ITAT ...
 
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