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TP - Assessee's explanations in respect of any amount cannot be discarded, without recording of findings that assessee has any other source of income & which hitherto has not been declared: ITAT (See 'Breaking News')

TP - Entity engaged in diversified activities and having incurred significant R&D expenditure and owning intangible assets, cannot be compared to pure ITES provider: ITAT (See 'Breaking News')

TP - Entity deriving income from trading activity and also maintaining inventories cannot be considered as good comparable to marketing support service provider: ITAT (See 'Breaking News')

I-T - Provisions of Section 206AA are applicable to recipient of income who is covered by DTAA between India and home country of such recipient: ITAT (See 'Breaking News')

TP - Expat support reimbursement cannot be treated as duplicative in nature, if taxpayer has earned income from its customers at cost plus markup after including cost of such services: ITAT (See 'Breaking News')

TP - It is fit case for remand where MAP resolution is passed much after assessment order being passed by AO: ITAT (See 'Breaking News')

Review of Foreign Direct Investment (FDI) Policy in Defence Sector (See 'Bulletin Bord')

TP - Functional dissimilarity and ownership over huge intangibles calls for exclusion of comparable: ITAT (See 'Breaking News')

TP - RPM cannot be applied for bechmarking international transactions between two AEs, if there are broad differences in functions performed and gross margins earned: ITAT (See 'Breaking News')

TP - Final assessment and transfer pricing order along with levy of penalty, passed by AO in garb of draft assessment without complying with mandate of Sec 144C, is invalid: ITAT (See 'Breaking News')

TP - High Court's writ jurisdiction cannot be invoked where assessee does not make strong case for waiver of efficacious alternate remedy of appeal: HC (See 'Breaking News')

GST - Breezily e-invoicing amidst COVID-19 - Voicing concerns crawling lately! (See 'The Cob(Web)' Column)

TP - Merchant banker cannot be compared to entities engaged in providing non-binding investment advisory services, for purposes of benchmarking: ITAT (See 'Breaking News')

TP - Where CUP method has consistently been applied in assessee's case over years for benchmarking purposes, adoption of TNMM in current AY is not sustainable: ITAT (See 'Breaking News')

TP - Order making TP adjustment is unsustainable where assessee is not given proper opportunity to file reply to Show Cause Notice & order is passed without TPO giving sufficient thought to assessee's replies: HC (See 'Breaking News')

TP - Excessive AMP expenditure of taxpayer cannot be treated as international transactions u/s 92B by merely applying BLT method, if such expenses are duly disclosed in Form 3CEB: ITAT (See 'Breaking News')

I-T - Payments for acquiring off-shelf software would be in nature of business profits in hands of non-resident if it does not have PE in India: ITAT (See 'Breaking News')

TP - Any action u/s 263 can be taken on account of infringement of an omitted provision, particularly when same is not protected by any saving clause: ITAT (See 'Breaking News')

TP - An ITE service provider and KPO service provider can be compared for purposes of ALP determination: ITAT (See 'Breaking News')

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Jaipur, Sep 22, 2020 By TII News Service
TP - Assessee's explanations in respect of any amount cannot be discarded, without recording of findings that assessee has any other source of in...

New Delhi, Sep 22, 2020 By TII News Service
TP - Entity engaged in diversified activities and having incurred significant R&D expenditure and owning intangible assets, cannot be compared to...

Bangalore, Sep 22, 2020 By TII News Service
TP - Entity deriving income from trading activity and also maintaining inventories cannot be considered as good comparable to marketing support s...

New Delhi, Sep 21, 2020 By TII News Service
TP - It is fit case for remand where MAP resolution is passed much after assessment order being passed by AO: ITAT ...

New Delhi, Sep 21, 2020 By TII News Service
TP - Expat support reimbursement cannot be treated as duplicative in nature, if taxpayer has earned income from its customers at cost plus markup...

Bangalore, Sep 21, 2020 By TII News Service
I-T - Provisions of Section 206AA are applicable to recipient of income who is covered by DTAA between India and home country of such recipient: ...

New Delhi, Sep 18, 2020 By TII News Service
TP - Functional dissimilarity and ownership over huge intangibles calls for exclusion of comparable: ITAT...

Mumbai, Sep 18, 2020 By TII News Service
TP - RPM cannot be applied for bechmarking international transactions between two AEs, if there are broad differences in functions performed and ...

New Delhi, Sep 18, 2020 By TII News Service
TP - Final assessment and transfer pricing order along with levy of penalty, passed by AO in garb of draft assessment without complying with mand...

Chennai, Sep 17, 2020 By TII News Service
TP - High Court's writ jurisdiction cannot be invoked where assessee does not make strong case for waiver of efficacious alternate remedy of appe...

Mumbai, Sep 17, 2020 By TII News Service
TP - Where CUP method has consistently been applied in assessee's case over years for benchmarking purposes, adoption of TNMM in current AY is no...

New Delhi, Sep 17, 2020 By TII News Service
TP - Excessive AMP expenditure of taxpayer cannot be treated as international transactions u/s 92B by merely applying BLT method, if such expense...

Mumbai, Sep 17, 2020 By TII News Service
TP - Merchant banker cannot be compared to entities engaged in providing non-binding investment advisory services, for purposes of benchmarking: ...

Chennai, Sep 16, 2020 By TII News Service
TP - Order making TP adjustment is unsustainable where assessee is not given proper opportunity to file reply to Show Cause Notice & order is pas...

Bangalore, Sep 16, 2020 By TII News Service
I-T - Payments for acquiring off-shelf software would be in nature of business profits in hands of non-resident if it does not have PE in India: ...

Kolkata, Sep 16, 2020 By TII News Service
TP - Any action u/s 263 can be taken on account of infringement of an omitted provision, particularly when same is not protected by any saving cl...

Bangalore, Sep 15, 2020 By TII News Service
TP - An ITE service provider and KPO service provider can be compared for purposes of ALP determination: ITAT ...

New Delhi, Sep 15, 2020 By TII News Service
TP - Functional dissimilarity is appropriate reason for exclusion of entity from list of comparables: ITAT...

Mumbai, Sep 15, 2020 By TII News Service
TP - In absence of express arrangement between taxpayer and its AE for incurring AMP expenditure to promote AE's brand, said transactions would n...

Chennai, Sep 14, 2020 By TII News Service
TP - Software company having huge turnover 23 times as that of assessee-company, captive service provider, cannot be adopted as comparable: HC ...

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