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TP - Uploading DRP directions on ITBA portal constitutes valid communication - mandatory one-month period u/s 144C(13) for completing assessment must be reckoned from end of month in which directions are received: ITAT (See Breaking News) I-T - Indian AE do not constitutes Dependent Agent PE of assessee in India under Article 5(5) of India-Switzerland DTAA, if AE does not habitually exercise authority to negotiate and conclude contracts on behalf of assessee: ITAT (See Breaking News) I-T - Compensation paid pursuant to out-of-court settlement is not hit by Explanation 1 to Sec 37(1): ITAT (See Breaking News) TP - Since clause (i) of section 92BA having been omitted by Finance Act, 2017 without any saving clause, any transfer pricing adjustment & reference to TPO made under the omitted clause, is non est in law: ITAT (See Breaking News) TP - LIBOR is appropriate rate of interest for benchmarking foreign currency loans advanced by assessee to its 100% subsidiaries, without any ad hoc mark-up: ITAT (See Breaking News) DTAA - In-house support involving coordination for bug-fixing, involves transfer of technology or technical know-how does not satisfy make available clause - consideration for such activity not Fees for Technical Services: ITAT (See Breaking News) I-T - Reimbursements of IT infrastructure & common software costs, salary expenses and travel expenses are of nature of cost-to-cost recharges without any profit element & do not constitute Fees for Technical Services liable to TDS u/s 195: ITAT (See Breaking News) TP - Fully & compulsorily convertible debentures remain hybrid instruments that function as debt until they are actually converted into equity shares: ITAT (See Breaking News)
 
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TP - Uploading DRP directions on ITBA portal constitutes valid communication - mandatory one-month period u/s 144C(13) for completing assessment ...
I-T - Indian AE do not constitutes Dependent Agent PE of assessee in India under Article 5(5) of India-Switzerland DTAA, if AE does not habituall...
I-T - Compensation paid pursuant to out-of-court settlement is not hit by Explanation 1 to Sec 37(1): ITAT ...
TP - Since clause (i) of section 92BA having been omitted by Finance Act, 2017 without any saving clause, any transfer pricing adjustment & refer...
TP - LIBOR is appropriate rate of interest for benchmarking foreign currency loans advanced by assessee to its 100% subsidiaries, without any ad ...
DTAA - In-house support involving coordination for bug-fixing, involves transfer of technology or technical know-how does not satisfy make availa...
I-T - Reimbursements of IT infrastructure & common software costs, salary expenses and travel expenses are of nature of cost-to-cost recharges wi...
TP - Fully & compulsorily convertible debentures remain hybrid instruments that function as debt until they are actually converted into equity sh...
I-T - Section 244A interest is not taxable at NIL under MFN clause importing India-US DTAA benefit: ITAT ...
TP - Reference u/s 92CA(1) is transaction-specific and does not confer upon TPO a general jurisdiction to determine assessee's taxable income or ...
I-T - Territorial jurisdiction is governed by location of AO who passed assessment order - cannot be conferred based on situs of First Appellate ...
TP - Notional interest adjustment on receivables is impermissible where receivables have not become overdue within relevant accounting period: IT...
TP - Assessee is entitled to challenge comparable before DRP even if it accepts the same before TPO - comparability is to be determined in keepin...
TP - Rate charged by State Electricity Board to industrial consumer should be taken as market value for transfer of electricity from eligible uni...
TP - TPO cannot reject assessee's selection of AE as tested party for export transactions and substituting GPL India as tested party: ITAT ...
I-T - Interest received from and paid to overseas head office and branches is not taxable at hands of PE applying doctrine of mutuality: ITAT ...
TP - Interest rate on intra-group loans should not be benchmarked using CUP method: ITAT ...
I-T - Mere fact that for limited purpose of attribution of profits under DTAA, a Permanent Establishment is treated as separate enterprise, does ...
TP - Mere attribution of percentages to functions, assets and risks, without reliable basis for quantifying respective economic contributions, ca...
TP - If assessee has filed financials of AEs to establish that payment received from assessee were subjected to taxation in their respective juri...
 
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