Thursday , June 21, 2018 |   17:40:33 IST
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Drive Against Shell Companies - A cul-de-sac! (See 'THE COB(WEB)' TIOL) TP - Claims for adopting foreign AE as tested party and selection of MAM, made during course of TP proceedings, should not be rejected by merely construing it as 'additional evidences': ITAT (See 'Breaking News') DTAA - Mere existence of subsidiary in India will not by itself construe it as PE, when no business operations are carried out by Indian entity in furtherance of its overseas parent company: ITAT (See 'Breaking News') DTAA - Receipts of UK entity for providing inspection & testing services are not taxable under Article 13(4)(c) of Indo-UK DTAA, if no technical know-how is made available in India: ITAT (See 'Breaking News') DTAA - Payments made abroad for rendering of market support services to foreign customers, are not taxable either under I-T Act or Treaty provisions without make-available clause: ITAT(See 'Breaking News') TP - Comparison cannot be made between company not part of ITES sector & pure software developer for benchmarking purposes: ITAT (See 'Breaking News') TP - Exclusion of company from comparables list based on Tribunal decision must entail no difference in conclusions of both benches: ITAT (See 'Breaking News') TP - Labour strike is not an extraordinary event justifying exclusion of concern if extraordinary cost incurred in this process is removed: ITAT (See 'Breaking News') Computation of interest - CBDT invites comments on amendment in Rule 10CB (See 'TII Brief') Govt relieves Nilimesh Baruah to join CTPA in OECD as Sr Advisor TP - Corporate Guarantee Extended During Stewardship Activities For Subsidiaries Is Not International Transaction Needing ALP Adjustment: ITAT (See 'Breaking News') I-T - TDS Need Not Be Deducted On Expenses Incurred By Manufacturer To Register Products Overseas & Without Examining Nature Of Expenditure: ITAT (See 'Breaking News') I-T - Order Need Not Be Recalled For Not Raising & Considering Treaty Provisions When Determining Taxability Of Certain Payments: ITAT (See 'Breaking News') More reforms required for more integrated Europe: OECD Reports (See 'TII Brief') TP - Appellate Revenue Authority is not bound to accept erroneous premise framed by TPO, simply because he was referred for determination of ALP in an international transaction: HC (See 'Breaking News')
 
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TP - Claims for adopting foreign AE as tested party and selection of MAM, made during course of TP proceedings, should not be rejected by merel...
DTAA - Mere existence of subsidiary in India will not by itself construe it as PE, when no business operations are carried out by Indian entity...
DTAA - Receipts of UK entity for providing inspection & testing services are not taxable under Article 13(4)(c) of Indo-UK DTAA, if no technica...
DTAA - Payments made abroad for rendering of market support services to foreign customers, are not taxable either under I-T Act or Treaty provi...
TP - Comparison cannot be made between company not part of ITES sector & pure software developer for benchmarking purposes: ITAT ...
TP - Exclusion of company from comparables list based on Tribunal decision must entail no difference in conclusions of both benches: ITAT...
TP - Labour strike is not an extraordinary event justifying exclusion of concern if extraordinary cost incurred in this process is removed: ITAT...
TP - Corporate guarantee extended during stewardship activities for subsidiaries is not international transaction needing ALP adjustment: ITAT...
I-T - TDS need not be deducted on expenses incurred by manufacturer to register products overseas & without examining nature of expenditure: ITAT...
I-T - Order need not be recalled for not raising & considering treaty provisions when determining taxability of certain payments: ITAT...
TP - LIBOR is appropriate rate of interest to benchmark loans provided by Indian enterprise to its overseas AEs in foreign currency: ITAT...
TP - Related party transactions undertaken by a company in reasonable limit, does not calls for its exclusion from list of comparables: ITAT...
I-T - Management charges paid by Indian Branch office to its overseas HO, does not comes within the purview of section 44C: ITAT...
DTAA - Taxability of any receipts from execution of work in India, in the hands of UAE entity, depends on existence of its PE in India: ITAT...
I-T - Remittances made abroad can be disallowed, if the taxpayer fails to establish actual rendering of services through documentary evidences: I...
I-T - Telecom charges and technical fee paid in foreign currency, needs to be reduced from total turnover while working out the claim for exempti...
TP - Company engaged into diversified activities being a big brand, cannot be compared to a routine captive service provider, that too in absen...
TP - AMP expenses incurred by Indian entity for promotion of its business cannot be termed as 'international transaction', in absence of any of...
TP - Extra ordinary events witnessed by a company during particular year, does not calls for its exclusion for comparable analysis, without pro...
TP - Company having fluctuating operating margin, are no good comparable for purposes of benchmarking: ITAT...
 
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