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INTL TAXATION INTL MISC TP FDI LIBRARY VISA BIPA NRI
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TP - Appeal can be dismissed as withdrawn by appellant itself and Revenue can have no objection to dismissal of assessee’s appeal: ITAT (See 'Breaking News') TP - Routine expenses incurred by taxpayer entity for its overseas AE de hors any 'arrangement' for incurring of AMP expenses for brand building of AE, does not call for ALP adjustment: ITAT (See 'Breaking News') TP - Data to be used for comparability analysis should be of same financial year in which international transactions were entered into by tested party: ITAT (See 'Breaking News') GST - Compensation Cess turning into poisoned chalice for States! (See 'The Cob(Web)' Column) TP - Arm's length rate of interest in case of loans advanced to AE's is to be determined on basis of rate of interest charged in countries where loan is received: ITAT I-T - Transaction which does not involve any transfer of intellectual property, does not attract tax on royalty: ITAT (See 'Breaking News') I-T- Matter warrants remand for determining as to whether the adjustment for delayed receivables from associated enterprises get subsumed in working capital adjustment: ITAT (See 'Breaking News') I-T- If transaction of the royalty expenses between the assessee and its Associated Enterprises, is international transaction then its arm's-length price can be determined only under the transfer pricing provisions and not under the provision of the section 40A(2)(b) - YES: ITAT (See 'Breaking News') I-T - Income received by non-resident assessee on account of transponder charges from customers in India is taxable as royalty: ITAT (See 'Breaking News') TP - 'Proviso' of Sec. 92C(4) would though be applicable in case where ALP was determined by AO, but same cannot be extended to determination of same by taxpayer: ITAT (See 'Breaking News') TP - Entity engaged in diversified activities cannot be selected for purpose of comparison, in absence of segmental bifurcation: ITAT (See 'Breaking News') TP - Assessment order passed in case of non-existent entity is void: ITAT (See 'Breaking News') TP - Where main relief is granted on basis of one reason, adjudication of exclusion of comparable company for other reasons may not be necessary: ITAT ('See 'Breakimg News') OECD Members agree on method for reporting debt relief as ODA (See 'TII Brief') BRICS Environment Ministers' meet calls for promoting circular economy (See 'Brief') TP - Data to be used for comparison should be data relating to same financial year in which international transactions were entered by tested party: ITAT (See 'Breaking News') I-T - Managerial services which did not make available any technical knowledge, skill, knowhow or processes to purchaser, do not fall under FTS: ITAT (See 'Breaking News') TP - Dismissal of appeal on ground of it being filed in name of non-existing company amalgamated with another entity, is sustainable, where court omits to consider order passed by HC in respect of such amalgamation & regarding automatic transfer of litigations of transferor companies into transferee company: HC (See 'Breaking News') I-T - Any adjustment on account of transfer pricing is warranted, where assessee reimburses actual interest expenses debited by bank to assessee's head office: HC (See 'Breaking News')
 
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