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NEWS FLASH
I-T - Payment of roaming charges did not require any deduction of tax at source u/s 194J and, hence, no disallowance could be made u/s 40(a)(ia): ITAT (See Breaking News)
INTL - Testing charges paid to foreign entities where not involving any human element, cannot be treated as Fees for Technical Services & no tax is deductible u/s 195: ITAT (See Breaking News)
DTAA - Recent shifting of family and new investments abroad will not outweigh ‘Centre Of Vital Interests' in India; DTAA Tie-Breaker Test shall be applied to determine Residency Status: ITAT (See Breaking News)
TP- Penalty u/s 271G cannot be levied merely for inadequate or improper benchmarking of transactions & where Revenue does not prove that assessee failed to furnish specific documents as per Sec 92D: ITAT (See Breaking News)
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Mumbai, Jan 14, 2026 By TII News Service
I-T - Payment of roaming charges did not require any deduction of tax at source u/s 194J and, hence, no disallowance could be made u/s 40(a)(ia):...
Lucknow, Jan 14, 2026 By TII News Service
INTL - Testing charges paid to foreign entities where not involving any human element, cannot be treated as Fees for Technical Services & no tax ...
Bengaluru, Jan 13, 2026 By TII News Service
DTAA - Recent shifting of family and new investments abroad will not outweigh ‘Centre Of Vital Interests' in India; DTAA Tie-Breaker Test shall...
Ahmedabad, Jan 13, 2026 By TII News Service
TP- Penalty u/s 271G cannot be levied merely for inadequate or improper benchmarking of transactions & where Revenue does not prove that assessee...
Mumbai, Jan 12, 2026 By TII News Service
DTAA - Interest on delayed payment of lease rental which is integral part of least rental charged by ireland entity is not taxable in India in te...
New Delhi, Jan 12, 2026 By TII News Service
TP - Penalty or compensation clauses in agreement may specifically quantify any liquidated damages or compensation, but enforceability of contrac...
New Delhi, Jan 09, 2026 By TII News Service
TP - Recovery on cost to cost basis without any service element, cannot be recharacterised by imputing adhoc markup: ITAT...
New Delhi, Jan 09, 2026 By TII News Service
TP - As per Section 144C, AO is required to complete assessment within 30 days of receiving directions from DRP & order passed beyond such period...
Mumbai, Jan 09, 2026 By TII News Service
I-T - Payment of roaming charges by cellular mobile telephony service provider to other telecom operators for subscribers does not attract Sec 9(...
Ahmedabad, Jan 08, 2026 By TII News Service
I-T - Not straying amount due to assessee, more particularly, when assessee is not entitled to any interest on such refund, is unjust enrichment ...
New Delhi, Jan 08, 2026 By TII News Service
DTAA - Payments of nature of salary cannot be re-characterized as FTS either under I-T Act or under Article 12 of India–Japan DTAA, which expre...
Bengaluru, Jan 08, 2026 By TII News Service
TP - If working capital adjustment subsumes outstanding receivables, no separate characterization is to be made on account of delayed receivables...
Bengaluru, Jan 07, 2026 By TII News Service
TP - Final assessment order passed before expiry of the 30-day window given to assessee to file objections against draft assessment order, is not...
Hyderabad, Jan 07, 2026 By TII News Service
TP - Differences in functional and turnover filter calls for exclusion of comparable: ITAT...
New Delhi, Jan 06, 2026 By TII News Service
I-T - Indian subsidiary does not become PE merely because of cross-transactions or outsourcing of back-office operations: HC...
Ahmedabad, Jan 06, 2026 By TII News Service
I-T - If factors influencing price are similar, same margin on operating cost, as agreed under MAP resolution between Indian and UK Competent Aut...
New Delhi, Jan 06, 2026 By TII News Service
TP - International transaction pertaining to AMP expenditure cannot be benchmarked by applying bright line test method: ITAT...
Mumbai, Jan 05, 2026 By TII News Service
DTAA - Broad definition of 'operational expenditure' under treaty covers such arrangements if substantiated by genuine commercial evidence and ar...
Ahmedabad, Jan 05, 2026 By TII News Service
I-T - Since commission agent was non-resident, and assessee has not deducted tax at source and adhered to DTAA, AO is not right in treating asses...
Mumbai, Jan 02, 2026 By TII News Service
DTAA - Additions framed not tenable where authorities omit to consider that said deposits were not income but redeposit of assessee's own funds: ...
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