Tuesday , August 20, 2019 |   22:04:20 IST
INTL TAXATION INTL MISC TP FDI LIBRARY VISA BIPA NRI
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(TP - Transfer pricing adjustment should be restricted to only value of international transaction pertaining to manufacturing operations: ITAT See 'Breaking News') DTAA - Referral fees earned by foreign concern for their services carried out abroad, cannot be attributed or held as having been "deemed to have accrued or arisen" to said foreign concern in India: ITAT (See 'Breaking News') TP - No penalty u/s 271G can be levied for non-furnishing of segmental information, without rendering any finding on segmental break-up submitted by taxpayer: ITAT (See 'Breaking News') I-T - If no expenditure on payment of upfront fee to Foreign company has been incurred by Indian taxpayer entity, then no deduction can be availed by it while filing I-T return: ITAT (See 'Breaking News') I-T - Commission paid to agents abroad for procuring export orders overseas, does not amount to FTS and hence does not attracts withholding tax liability u/s 195: ITAT (See 'Breaking News') CBDT clarifies on treatment of farm-in expenditure of E&P Companies (See 'Bulletin Board') TP - TPO cannot question quantum of benefit accrued to taxpayer entity, for deciding ALP of Intra group services & royalty payments made to overseas AEs: ITAT (See 'Breaking News') TP - Company having huge brand value & ownership over intellectual property, are not comparable to captive BPO service providers: ITAT (See 'Breaking News') DTAA - Subscription fees received by non-resident entity from its Indian customers/subscribers has to be assessed as 'royalty': ITAT (See 'Breaking News') I-T - Once MAP resolution regarding attribution of profits of PE in India stands agreed between Competent Authorities, then matter regarding presence of PE calls for remand: ITAT (See 'Breaking News') I-T - Disallowance u/s 40(a)(i) cannot be imposed on royalty payments without verifying if taxpayer has deducted or not deducted TDS at time of payment to non-resident: HC (See 'Breaking News') BEPS - India notifies MLI as per agreement signed in Paris (See 'MLI' in 'INTL Taxation') Vanishing Demand makes Recession for Real! Tax Regime also contributes! (See 'THE COB(WEB)' in TIOL) I-T - No TDS u/s 195 is attracted to payments made overseas, if services were rendered outside India and payment was also received abroad: ITAT (See 'Breaking News') I-T - Payments made abroad for purchasing software without acquiring any copyright, does amount to royalty and hence does not attract TDS liability: ITAT (See 'Breaking News') TP - Inability to produce segmental profits due to trade difficulties in diamond industry, does not justify levy of penalty u/s 271G, if there is due compliance of Section 92CA & 92D: ITAT (See 'Breaking News') TP - Confirmation of ALP adjustment & transfer pricing additions in appellate proceedings by FAA, without resorting to independent application of mind, calls for remand: ITAT (See 'Breaking News') I-T- Merely because the Department's Non-filers Monitoring System issues a notice to the assessee the Revenue is at liberty to issue notice u/s 147 - NO: HC (See 'Breaking News') Multilateral Instrument - The clock is ticking!! (See 'TII Special')
 
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