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OECD labour force participation rate remains high in Q3 of 2025 (See Brief) I-T- Income from rig hire charges are to be computed under presumptive taxation provisions of Section 44BB of the Act: ITAT (See Breaking News) TP - Provision of negative lien on receivables & Participating Interest is not equivalent to providing a corporate guarantee; such arrangement is not an international transaction u/s 92B & warrants no benchmarking: ITAT (See Breaking News) DTAA - Capital gain derived from sale of unlisted equity shares of foreign entity pursuant to impermissible arrangement, is not entitled to treaty exemption: SC (See Breaking News) DTAA - Furnishing of services through employees within Contracting State is not enough, and ‘physical presence' is mandated, for rendering any counterpart as PE: HC (See Breaking News) I-T - AO, while deciding application for lower or nil withholding certificate u/s 197, is statutorily obligated to follow decision-making process prescribed under Rule 28AA: HC (See Breaking News) I-T- Non-compliance with sanctioning authority provisions post-April 2021 amendments go to the root of the jurisdiction, rendering the reassessment void : ITAT (See Breaking News) TP - Interest on rupee-denominated CCDs has to be benchmarked with reference to domestic prime lending rate & not LIBOR-based rates: ITAT (See Breaking News) 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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Breaking News
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I-T- Income from rig hire charges are to be computed under presumptive taxation provisions of Section 44BB of the Act: ITAT ...
TP - Provision of negative lien on receivables & Participating Interest is not equivalent to providing a corporate guarantee; such arrangement is...
DTAA - Capital gain derived from sale of unlisted equity shares of foreign entity pursuant to impermissible arrangement, is not entitled to treat...
DTAA - Furnishing of services through employees within Contracting State is not enough, and ‘physical presence' is mandated, for rendering any ...
I-T - AO, while deciding application for lower or nil withholding certificate u/s 197, is statutorily obligated to follow decision-making process...
I-T- Non-compliance with sanctioning authority provisions post-April 2021 amendments go to the root of the jurisdiction, rendering the reassessme...
TP - Interest on rupee-denominated CCDs has to be benchmarked with reference to domestic prime lending rate & not LIBOR-based rates: ITAT ...
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):...
INTL - Testing charges paid to foreign entities where not involving any human element, cannot be treated as Fees for Technical Services & no tax ...
DTAA - Recent shifting of family and new investments abroad will not outweigh ‘Centre Of Vital Interests' in India; DTAA Tie-Breaker Test shall...
TP- Penalty u/s 271G cannot be levied merely for inadequate or improper benchmarking of transactions & where Revenue does not prove that assessee...
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...
TP - Penalty or compensation clauses in agreement may specifically quantify any liquidated damages or compensation, but enforceability of contrac...
TP - Recovery on cost to cost basis without any service element, cannot be recharacterised by imputing adhoc markup: ITAT...
TP - As per Section 144C, AO is required to complete assessment within 30 days of receiving directions from DRP & order passed beyond such period...
I-T - Payment of roaming charges by cellular mobile telephony service provider to other telecom operators for subscribers does not attract Sec 9(...
I-T - Not straying amount due to assessee, more particularly, when assessee is not entitled to any interest on such refund, is unjust enrichment ...
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...
TP - If working capital adjustment subsumes outstanding receivables, no separate characterization is to be made on account of delayed receivables...
TP - Final assessment order passed before expiry of the 30-day window given to assessee to file objections against draft assessment order, is not...
 
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