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TP - If company's financials show predominantly software development service income and it satisfies all quantitative filters, denial of inclusion merely because it provides ancillary support services is not justified: ITAT (See Breaking News) TP - ALP for benchmarking electricity transactions should include gross rate charged by State Electricity Authority, which includes mandatory charges such as demand and penal charges: ITAT (See Breaking News) DTAA - Provisions of the DTAA are not triggered by DDT paid by a domestic company u/s 115-O: ITAT (See Breaking News) I-T - Proviso to Sec 149 provides that up to A.Y 2021-22 (period before amendment), period of limitation as prescribed in erstwhile provisions of Section 149(1)(b) would be applicable: ITAT (See Breaking News) I-T - Income from distribution of standardized software products by distributor, who does not own intellectual property, cannot be characterized as FTS: ITAT (See Breaking News) I-T - If international transactions between parties relating to non-exclusive distributorship and sale of software, were found to be at arm's length, no further attribution of profit can be made to PE: ITAT (See Breaking News) INTL - Interest paid u/s 201(1A) for delayed deposit of TDS is not compensatory in nature & does not qualify as allowable business expenditure u/s 37(1): ITAT (See Breaking News) INTL - Disallowance u/s 40(a)(i) sustainable where assessee paid a substantial sum to an international consultant, thereby creating an employer-employee relationship attracting TDS u/s 192: ITAT (See Breaking News) I-T - Procedure u/s 144C(1) has to be followed by Assessing Officer only if he proposes to make any variation which is prejudicial to interest of eligible assessee: ITAT (See Breaking News)
 
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Bengaluru, Feb 06, 2026 By TII News Service
TP - If company's financials show predominantly software development service income and it satisfies all quantitative filters, denial of inclusio...
Hyderabad, Feb 06, 2026 By TII News Service
TP - ALP for benchmarking electricity transactions should include gross rate charged by State Electricity Authority, which includes mandatory cha...
Mumbai, Feb 05, 2026 By TII News Service
DTAA - Provisions of the DTAA are not triggered by DDT paid by a domestic company u/s 115-O: ITAT ...
Mumbai, Feb 05, 2026 By TII News Service
I-T - Proviso to Sec 149 provides that up to A.Y 2021-22 (period before amendment), period of limitation as prescribed in erstwhile provisions of...
Mumbai, Feb 04, 2026 By TII News Service
I-T - Income from distribution of standardized software products by distributor, who does not own intellectual property, cannot be characterized ...
New Delhi, Feb 04, 2026 By TII News Service
I-T - If international transactions between parties relating to non-exclusive distributorship and sale of software, were found to be at arm's len...
Hyderabad, Feb 03, 2026 By TII News Service
INTL - Interest paid u/s 201(1A) for delayed deposit of TDS is not compensatory in nature & does not qualify as allowable business expenditure u/...
Hyderabad, Feb 03, 2026 By TII News Service
INTL - Disallowance u/s 40(a)(i) sustainable where assessee paid a substantial sum to an international consultant, thereby creating an employer-e...
Hyderabad, Feb 03, 2026 By TII News Service
I-T - Procedure u/s 144C(1) has to be followed by Assessing Officer only if he proposes to make any variation which is prejudicial to interest of...
New Delhi, Feb 02, 2026 By TII News Service
I-T - Simply because power of attorney was given to person residing in India, company incorporated outside India, cannot be held to be company re...
Mumbai, Feb 02, 2026 By TII News Service
TP - If RHQ charges allocated to both segments are forming part of cost base of these segments respectively and by adopting aggregation approach,...
Hyderabad, Feb 02, 2026 By TII News Service
TP - Upper time limit for passing final assessment order u/s 143(3) r.w.s. 144C(13) r.w.s. 144B, is governed by provisions of Sec 153(1) and Sec ...
Mumbai, Jan 30, 2026 By TII News Service
DTAA - As is trite law, additions based solely on internal identifiers like BUP IDs & presumptive deposits are unsustainable: ITAT ...
Pune, Jan 29, 2026 By TII News Service
TP - Where clause (i) of section 92BA, was omitted vide the Finance Act, 2017, it cannot then be applied onto ongoing proceedings to frame TP adj...
New Delhi, Jan 29, 2026 By TII News Service
TP - Payment of technical support service charges by assessee to its AEs with mark up of 5% over and above actual cost incurred by AEs is to be a...
Pune, Jan 28, 2026 By TII News Service
DTAA - Filing of Form 67 is a procedural or directory requirement & not mandatory in nature: ITAT ...
Mumbai, Jan 28, 2026 By TII News Service
I-T - If assessee had borrowed money from partnership firm and repaid loan, without deriving any benefit, such transactions resulting in merely t...
New Delhi, Jan 27, 2026 By TII News Service
DTAA - Services of developing technologies & collaborating with academic institutions, involve transfer of technical knowledge or expertise so as...
New Delhi, Jan 27, 2026 By TII News Service
TP - Where impact of extended credit period is subsumed within working capital adjustment while benchmarking operating margins, separate adjustme...
New Delhi, Jan 27, 2026 By TII News Service
TP - Incentive granted under state industrial policy is capital subsidy aimed at promoting industrial development in backward areas & so qualifie...
 
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