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INTL TAXATION INTL MISC TP FDI LIBRARY VISA BIPA NRI
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TP - Disagreement over application of benchmarking method, would not amount to question of law, unless it is established that such application resulted in distorted outcome: HC (See 'Breaking News') TP - Royalty paid by AEs to their parent group company, cannot be treated as capital expenditure: ITAT (See 'Breaking News') DTAA - Global corporate guarantee agreement entered with NRI company for securing loans to AEs, cannot be treated as business profit: ITAT (See 'Breaking News') I-T - Mere failure to record detailed discussion in consequential order, is not sufficient to hold that AO has decided to allow expenditure without verification: ITAT (See 'Breaking News') TP - Rate of interest in case of pending receivables from AEs should be determined by applying LIBOR plus suitable basis point keeping in view credit score of AEs: ITAT (See 'Breaking News') TP - When determination of ALP in appeal effect order did not lead to any TP adjustment, with no effect on income of Assessee, no penalty provisions is applicable in such case: ITAT (See 'Breaking News') I-T - Overseas payment received as consideration for use of, or right to use industrial or scientific equipment, will fall within realm of 'Royalty' as per DTAA: ITAT (See 'Breaking News') TP - Outstanding receivables from AE prior to amendment of Finance Act, 2012, cannot be considered as 'international transaction' u/s 92B: ITAT (See 'Breaking News') Action 5 - Report on 44 tax jurisdictions released ( See ' Brief') TP - Extraordinary event of acquisition which has affected profit level indicator, is no ground for exclusion of comparable: ITAT (See 'Breaking News') TP - TNMM adopted for determination of ALP will only cover broad functional & product or services comparability & will involve comparison of margins at net profit level: ITAT (See 'Breaking News') TP - TP study of Assessee cannot be rejected by TPO and Assessee cannot be directed to establish benefit derived by it from AEs, when no TP examination was carried by TPO: ITAT (See 'Breaking News') Revamped GST calls for change in Basic Design! (See 'The Cob(Web)' in TIOL) I-T - No TDS is mandated on payments made to foreign residents for activities connected with business & directly related to earning of income from sources outside India: ITAT (See 'Breaking News') I-T - Provisions of section 147 can be triggered, in absence of any reason to believe escapement of income: ITAT (See 'Breaking News') I-T - No interest is imposable u/s 234B for failure of payer to deduct TDS, if advance tax paid by him including TDS was less than the amount he was obliged to pay: ITAT (See 'Breaking News') South Korea, Macau & UAE figure in list of 17 tax haven blacklisted by EU (See TII Brief')
 
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