Wednesday , December 24, 2025 |   00:08:17 IST INTL TAXATION Case LawsDTAA Circulars (I-T Act, 1922) Limited Treaties Other Treaties TIEAs Notifications Circulars Relevant Sections of I-T Rules,1962 Instructions Administrative Orders DRP Panel I-T Act, 1961 MLI Relevant Portion of I-T Act,1922 GAAR MAP INTL MISC Case LawsOECD Conventions Draft Guidelines DTC Bill Committee Reports FATCA Intl-Taxation Finance Acts Manual on EoI UN Model Taxation Miscellaneous Cost Inflation Index Union Budget Information Security Guidelines TP Case LawsAPA Annual Report APA Rules Miscellaneous Relevant Sections of Act Instructions Circulars Notifications Draft Notifications Forms TP Rules APA FAQ UN Manual on TP Safe Harbour Rules US Transfer Pricing FDI Case LawsFEMA Act Fema Notifications Master Circulars Press Notes Rules FDI Circulars RBI Circulars Reports FDI Approved RBI Other Notifications FIPB Review FEO Act LIBRARY Company CasesCBR Act NBFC Report INTELLECTUAL PROPERTY Black Money Act PMLA Instruction PMLA Bill FM Budget Speeches Multimodal Transportation Vienna Convention EXIM Bank LoC Manufacturing Policy FTDR Act, 1992 White Paper on Black Money Transfer of Property MCA Circular Limitation Act VISA Type of Visa SSAs EPFO Acts FAQs Rules Guidelines Tourist Visa Notifications BIPA Arbitration Model Text Agreements NRI Case LawsRelevant Portion of I-T Act I-T Rules, 1962 Circulars MISC Notification About Us Contact Us Newsletters

NEWS FLASH   I-T - Taxpayer has right to rely on treaty provisions and question of touching brought forward capital losses does not arise in subsequent AYs once eligibility to carry these losses forward was determined in year they were suffered: ITAT (See Breaking News) TP - Mere failure to satisfy need/purpose/benefit/rendition test alone is no basis to disallow intra group services between AEs: ITAT (See Breaking News) Treaty-shopping: Nepal ejects Mauritius out of its cart (See TII Edit) TP - Resale price method is most appropriate for benchmarking international transaction in its distribution segment: ITAT (See Breaking News) TP - CIT(A) ought not to have restored matter back to AO under mistaken view that it was ex-parte order: ITAT (See Breaking News) I-T - 'Test of imparting' is touchstone if foreign entity continues to use its own industrial and commercial experience to render services, and essence of royalty lies in alienation, not in application: ITAT (See Breaking News) I-T - Reimbursements of expenses made on cost to cost basis, i.e. without any markup, cannot be treated as FIS, in absence of make available clause: ITAT (See Breaking News) I-T - No attribution of profit can be made to PE when there is no existence of PE at all: ITAT (See Breaking News) I-T - Payments made for providing standard facility for data processing without any human intervention, is not taxable in India as FTS in terms of Sec 9(1)(vii): ITAT (See Breaking News) I-T - Receipts from distribution activity is not royalty in absence of dependent agent PE: ITAT (See Breaking News) TP - If there was no value addition, and assessee only sought reimbursement of expenses on cost to cost basis, no ALP adjustment is permitted on account of same: ITAT (See Breaking News) DTAA - Concepts like virtual PE or Significant Economic Presence, while reflecting evolving international taxation trends, cannot be judicially read into a DTAA, absent express amendment: HC (See Breaking News) DTAA - OECD materials and practices of other jurisdictions are not relevant against clear language in relevant DTAA: HC (See Breaking News) I-T - Mismatches in limbs of provisions of section 271(1)(c) renders levy of penalty invalid: ITAT (See Breaking News)   SIGN IN   Username Password Forgot Password   Home >> Case Law Details     Member Login         Username :   Password :        Forgot Password

INTL TAXATION INTL MISC TP FDI LIBRARY VISA BIPA NRI TII DTAA Circulars (I-T Act, 1922) Limited Treaties Other Treaties TIEAs Notifications Circulars Relevant Sections of I-T Rules,1962 Instructions Administrative Orders DRP Panel I-T Act, 1961 MLI Relevant Portion of I-T Act,1922 GAAR MAP OECD Conventions Draft Guidelines DTC Bill Committee Reports FATCA Intl-Taxation Finance Acts Manual on EoI UN Model Taxation Miscellaneous Cost Inflation Index Union Budget Information Security Guidelines APA Annual Report APA Rules Miscellaneous Relevant Sections of Act Instructions Circulars Notifications Draft Notifications Forms TP Rules APA FAQ UN Manual on TP Safe Harbour Rules US Transfer Pricing FEMA Act Exchange Manual Fema Notifications Master Circulars Press Notes Rules FDI Circulars RBI Circulars Reports FDI Approved RBI Other Notifications FIPB Review FEO Act INTELLECTUAL PROPERTY CBR Act NBFC Report Black Money Act PMLA Instruction PMLA Bill FM Budget Speeches Multimodal Transportation Vienna Convention EXIM Bank LoC Manufacturing Policy FTDR Act, 1992 White Paper on Black Money Posting Policy PMLA Cases Transfer of Property MCA Circular Limitation Act Type of Visa SSAs EPFO Acts FAQs Rules Guidelines Tourist Visa Notifications Arbitration Model Text Agreements Relevant Portion of I-T Act I-T Rules, 1962 Circulars MISC Notification About Us Contact Us     A Taxindiaonline Website. Copyright © 2010-2025 | Privacy Policy | Taxindiainternational.com Pvt. Ltd. OPC All rights reserved. TIOL GROUP WEBSITES