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INTL TAXATION INTL MISC TP FDI LIBRARY VISA BIPA NRI
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TP - DRP not liable for reducing an adjustment when TPO himself on being satisfied has carried out such reduction: ITAT (See 'Breaking News') TP - profits/losses of speculative transactions can be set off against normal business profits/losses if such transactions are incidental to main business of assessee: ITAT (See 'Breaking News') Govt approves six proposals of FDI (See 'FDI Approved' in FDI) TP - RPM most suitable for distributor obtaining goods/services from AE and reselling without making any value addition: ITAT (See 'Breaking News') TP - Distribution activity & AMP expenses are two separate but related international transactions and should be aggregated only for determining their ALP: ITAT (See 'Breaking News') UAE signs pact for Assistance in Tax Matters (See 'TII Brief') Clarification on removal of Cyprus from the list of notified jurisdictional areas under section 94A of the Income tax Act, 1961 (See 'Circular' in Intl Taxation) USD 250 bn Tax Bill - Australian Federal Court rules against Chevron TP - 'Guarantee commission' would be construed as 'international transaction' u/s 92B, if AE was charged lesser interest in case of credit taken against guarantee: ITAT (See 'Breaking News') TP - Adjustment on account of underutillization of margins should be made while computing ALP, if underutilization is more than average underutilization of industry: ITAT (See 'Breaking News') The Insolvency and Bankruptcy Code, 2016 (IBC) (See 'CORP EINSICHT' in TIOLCorplaws.com) I-T - Contribution made by member to its mutual association by way of foreign remittances, would not constitute income chargeable to tax: ITAT (See 'Breaking News') France - new tax haven for India? (See 'TII Edit') TP - No gaint company having huge intangibles & IPR can be compared to any average entity: ITAT (See 'Breaking News') I-T - TDS u/s 195 is mandated on consultancy fee paid to foreign company, who had deputed their skilled employees to India to render services to assessee: ITAT (See 'Breaking News')
 
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TP - DRP not liable for reducing an adjustment when TPO himself on being satisfied has carried out such reduction: ITAT...
TP - profits/losses of speculative transactions can be set off against normal business profits/losses if such transactions are incidental to main...
TP - RPM most suitable for distributor obtaining goods/services from AE and reselling without making any value addition: ITAT...
TP - Distribution activity & AMP expenses are two separate but related international transactions and should be aggregated only for determining t...
TP - 'Guarantee commission' would be construed as 'international transaction' u/s 92B, if AE was charged lesser interest in case of credit taken ...
TP - Adjustment on account of underutillization of margins should be made while computing ALP, if underutilization is more than average underutil...
I-T - Contribution made by member to its mutual association by way of foreign remittances, would not constitute income chargeable to tax: ITAT...
TP - No gaint company having huge intangibles & IPR can be compared to any average entity: ITAT...
I-T - TDS u/s 195 is mandated on consultancy fee paid to foreign company, who had deputed their skilled employees to India to render services to ...
I-T - In case services rendered are in excess of billed services, revenue has to be recognized irrespective of it being not billed as at year-end...
TP - For benchmarking, a company registered with SEBI as merchant banker cannot be compared with a company engaged in investment advisory service...
I-T - In case an adverse ruling has already been made by similar writ court with regard to an issue raised by Revenue, no further interference is...
TP - It is substance and not nomenclature of an expense incurred that is determinative of actual nature of amount incurred with relation to a bu...
TP - Need & benefit test for determination of ALP of certain intra group services is satisfied when such test already stood satisfied in previou...
TP - It cannot be said that functional similarity of companies to be selected as comparables is of no importance, if TNMM has been used for ALP d...
TP - As per directions of DRP, TPO/AO is bound to give effect to them, irrespective of fact whether they are acceptable to department or not - YE...
TP - Rate of payment of royalty approved by RBI would not 'ipso-facto' constitute ALP under TP regulations as provided in Chapter X of Act - ITAT...
TP - Services in connection with advertisement cost incurred outside India whose benefit is accrued to foreign AE, cannot be claimed by assessee ...
I-T - If there is no covenant granting exclusive rights of technical know-how, expenditure so incurred in that regard cannot be treated as capita...
TP - If AO while allowing weighted deduction u/s 35(2AB) has merely relied upon previous year's order, he cannot deny subsequently on no cogent b...
 
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