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DTAA - Project office acting as communication channel to support Non-resident entity's main activity of fabrication & installation of platforms, cannot be construed as PE: HC (See 'Breaking News')

TP - Company engaged in rendering highly technical service cannot be compared to captive service providers engaged in rendering mere support services: ITAT (See 'Breaking News')

TP - Losses suffered by entity in a particular assessment year, will not be construed as persistent losses so as to refer it as unfit for purposes of comparison: ITAT (See 'Breaking News')

Hyderabad Encounter - How Instant can be 'Instant Justice'? See ('The Cob(Web)')

I-T - Profit earned by overseas HO to Indian Branches cannot be taxed in India unless they are attributable to Indian Branches, and hence no adjustment is called for: ITAT (See 'Breaking News')

TP - If impact of receivables on working capital and thereby on its profitability already stands factored, no further adjustment is warranted on basis of outstanding receivables: ITAT (See 'Breaking News')

I-T - Legal findings rendered by Full Bench of High Court after discussing all relevant facts & judgments, cannot be questioned by way of review, on frivolous grounds: HC (See 'Breaking News')

Cabinet nod for Agreement on Social Security between India and Brazil (See 'TII Brief')

TP - Concern which is engaged in diversifying field and whose financial segmental is also not available, is unfit for purposes of comparison: ITAT (See 'Breaking News')

TPO is not permited to impose penalty u/s 271G if on date of non-compliance of notice as required u/s 92D(3), only AO was having such statutory power: ITAT (See 'Breaking News')

TP - Simply because one concern was wrongly not considered by taxpayer as comparable, cannot act as deterrent for claiming same as comparable and be considered for evaluation: ITAT (See 'Breaking News')

I-T - Outstanding demand merits interim stay after compliance of pre deposit, in case of dispute relating to application of amendment to respective provision which will decide scope of tax liaibility: ITAT (See 'Breaking News')

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Miscellaneous

Untitled Document

ICAI Guidelines

PRI To The United Nations

Guidance note on report under section 92E of the Income-Tax ACT, 1961

PRI To The United Nations

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