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Development of Transfer Pricing Law (See 'TII Special') TP - Deeming fiction of Section 92B & 92C cannot be invoked when none of AEs are non-residents: ITAT (See 'Breaking News') I-T - Interest received by Indian Branch of foreign Bank from its HO does not give rise to any income which is taxable in India because one could not make profit out of itself: ITAT (See 'Breaking News') Vodafone verdict - Govt to 'study' arbitration award (See 'Brief') TP - Specific segmental functionality is required to be obtained by TPO, before deciding comparability of any entity: ITAT (See 'Breaking News') TP - ALP adjustment made without following due procedure contemplated u/s 92CA r/w Rule 10B, merits deletion: ITAT (See 'Breaking News') TP - Functional dissimilarity backed by absence of segmental information, calls for exclusion of comparable: ITAT (See 'Breaking News') Further change in residency rules: Three attempts (and counting)? (See 'TII Edit') EU Commission resolves to go ahead with digital tax if OECD fails to broker global consensus COVID-19 & Digital Technologies eat up romance of 'OFFICE' & also sovereignty to levy taxes! (See 'The Cob(Web' Column) I-T - Service such as inspection of goods & their timely dispatch, provided by non-resident company to to Indian assessee, requires any technical knowledge: HC (See 'Breaking News') TP - If international transaction reported by taxpayer in its Form 3CEB stands identified and examined by TPO to be true, then nature of services cannot be re-characterized: ITAT (See 'Breaking News') TP - Once taxpayer had paid for support services rendered by AE and such payments have been accepted by TPO, then such services cannot be treated as 'duplicative in nature': ITAT (See 'Breaking News') TP - Assessee's explanations in respect of any amount cannot be discarded, without recording of findings that assessee has any other source of income & which hitherto has not been declared: ITAT (See 'Breaking News') TP - Certain companies warrant being excluded from list of comparables for purposes of benchmarking, where such companies witnesses occurance of extraordinary events during relevant AY: ITAT (See 'Breaking News') TP - ALP adjustment, for notional interest, on delay in realisation of trade debts from AEs is to be made where no interest is charged from non-AEs: ITAT (See 'Breaking News') TP - Companies having high brand value and very high turnovers, can be adopted as comparables to company engaged in providing ITeS to its AEs: ITAT (See 'Breaking News')
 
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