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TP - Economic adjustments for non-creditable customs duties and working capital cycles are mandatory to ensure comparability: ITAT (See Breaking News) TP - Parity must be maintained between operating cost and income base, specifically regarding ESOP reimbursements & foreign currency receivables: ITAT (See Breaking News) TP - TNMM is preferred over CUP method if there are significant contractual and economic differences between AE & non-AE transactions that cannot be accurately adjusted: ITAT (See Breaking News) I-T - Section 44C is an exhaustive provision for head office expenses meeting a specific tripartite test - YES: ITAT (See Breaking News) I-T - Foreign taxes paid, such as Japanese Inhabitant or Enterprise taxes, that do not qualify for credit u/s 90/91, are allowable as business expenditure u/s 37(1) r/w Explanation 1 to Sec 40(a)(ii): ITAT (See Breaking News) TP - If entity is debt-free, it cannot be presumed that borrowed funds were utilized to provide credit facilities to AEs : ITAT (See Breaking News) TP - Profit margin agreed upon in Bilateral APA for specific AEs constitutes reliable benchmark for determining ALP of similar transactions with non-covered AEs: ITAT (See Breaking News) TP - Once closely linked transactions are validly benchmarked under TNMM, segregating one component such as intra-group services for separate benchmarking can lead to impermissible double adjustment: ITAT (See Breaking News) TP - In back-to-back project execution model, CUP is appropriate method for benchmarking, and TNMM cannot be forced merely by treating Indian project office as captive sub-contractor: ITAT (See Breaking News)
 
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TP - Economic adjustments for non-creditable customs duties and working capital cycles are mandatory to ensure comparability: ITAT ...
TP - Parity must be maintained between operating cost and income base, specifically regarding ESOP reimbursements & foreign currency receivables:...
TP - TNMM is preferred over CUP method if there are significant contractual and economic differences between AE & non-AE transactions that cannot...
I-T - Section 44C is an exhaustive provision for head office expenses meeting a specific tripartite test - YES: ITAT ...
I-T - Foreign taxes paid, such as Japanese Inhabitant or Enterprise taxes, that do not qualify for credit u/s 90/91, are allowable as business ex...
TP - If entity is debt-free, it cannot be presumed that borrowed funds were utilized to provide credit facilities to AEs : ITAT ...
TP - Profit margin agreed upon in Bilateral APA for specific AEs constitutes reliable benchmark for determining ALP of similar transactions with ...
TP - Once closely linked transactions are validly benchmarked under TNMM, segregating one component such as intra-group services for separate ben...
TP - In back-to-back project execution model, CUP is appropriate method for benchmarking, and TNMM cannot be forced merely by treating Indian pro...
I-T - Statutory time limits for completing assessments u/s 153 are mandatory in DRP proceedings : ITAT ...
TP - ALP rate of interest on loan advanced to AEs shall be determined based on interest rate charged in country where loan is received: ITAT ...
I-T - Pure reimbursement of actual expenses on cost-to-cost basis without any profit element does not constitute taxable income and cannot be cla...
I-T - Reimbursement of salary costs for seconded employees on cost-to-cost basis does not constitute FTS if Indian entity acts as economic employ...
I-T – Beneficial tax rates on dividends provided under DTAA override domestic Dividend Distribution Tax rates u/s 115-O of Income-tax Act: ITAT...
DTAA - A transaction is taxable in India where no income arising from such transaction is taxed in India, no profits is attributed to PE in India...
I-T - ESOP expenses quantified under fair value method are allowable deductions u/s 37: ITAT ...
I-T - Capital gains from sale of shares in real estate company are taxable only in state of residence if investment is minority holding: ITAT ...
I-T - Additional claim for treaty relief u/s 90 cannot be admitted for first time before Tribunal if its determination depends on mandatory factu...
TP - Comparables must satisfy filters adopted for benchmarking, including RPT threshold, functional comparability, availability of segmental data...
TP - Omission of clause (i) of Sec 92BA by Finance Act, 2017, without any saving clause, renders it retrospectively inoperative from date of its ...
 
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