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DTAA - Income from technical handling services is not taxable in India as it is covered under Art 8(2) r/w Art 8(1) of Indo France Treaty: ITAT ...
TP - Amortization of goodwill arising out of merger & acquisition is extraordinary, non-recurring item not arising from normal business operation...
TP - Company functionally dissimilar to assessee, such as one engaged in high-end technical consultancy, cannot be retained as comparable for ben...
I-T - Denial of foreign tax credit merely on account of delay in filing Form No. 67 is not justified, as requirement of filing such form is direc...
TP - Both TPO & DRP function as authorities subordinate to AO & are not parties before ITAT, ergo, directions of ITAT should ordinarily be routed...
TP - An interim stay on a judgment does not erase its ratio: ITAT ...
I-T - Addition u/s 68 is unsustainable where the relevant receipts were duly recorded as sales in regular books of account & supported by documen...
I-T - Proceedings initiated and finalized on grounds beyond recorded reasons constitute over-exercise of jurisdiction and are void ab initio for ...
INTL - Limitation prescribed u/s 153 is applicable even in cases covered by section 144C & both provisions must be read harmoniously: ITAT ...
I-T - Non-obstante clause u/s 144C(13) imposes restriction on AO and denies him benefit of more expansive time-limit available u/s 153: ITAT ...
I-T - Certain share transactions cannot be deemed to be bogus merely on suspicion based on general modus operandi of penny stock cases, but witho...
I-T - Remittance of one's own money earned abroad and subjected to tax in foreign jurisdiction cannot be treated as income taxable in India in ab...
TP - Price at which industrial units purchase power from State Electricity Board can be applied as valid CUP for determining ALP of supply of pow...
DTAA - Subscription fees for access to database do not amount to royalty as there is no transfer of copyright but only use of copyrighted article...
I-T - DDT is tax on dividend income of shareholder, require consideration by Larger Bench: HC ...
DTAA - Assessee, being a Mauritius resident with valid TRC & no Permanent Establishment in India, is entitled to treaty benefits & exemption u/s ...
I-T - Decision to restore matter to AO shall in no way be construed as reflection or expression on merits of dispute: ITAT...
DTAA - Amount received for fabrication/refurbishing services (bushings) provided by foreign AE to Indian arm, is not fees for technical service, ...
I-T - Order of interim stay stays operative part of decision but does not wipe out its ratio decidendi or nullify precedent unless explicitly set...
I-T - Final assessment in name of non-existent entity, i.e., amalgamating company that had ceased to exist pursuant to NCLT-approved scheme of am...
 
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