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TP - Functional dissimilarity is enough ground for rejection of comparable: ITAT (See 'Breaking News')

TP - e-connectivity charges paid by assessee-company to its parent company abroad is allowed as revenue expenses & on which deduction is allowed: ITAT (See 'Breaking News')

Post-COVID-19 - New World Order - 'Chini Kum' if eye is on rule-based stability! (See 'The Cob(Web) Column')

I-T : Provision of Guarantee fees service is not fee for Technical services under India - Netherlands DTAA: ITAT (See 'Breaking News')

TP - In terms of rule 10B(l)(e)(i), any addition can be made on notional basis, whether cost incurred by AE can be added financial statement of assessee: ITAT (See 'Breaking News')

I-T - Depreciation is allowed in respect of such expenses: ITAT (See 'Breaking News')

TP - Consistent method followed & accepted in transfer pricing proceedings, can be changed without there being any change in facts or law: ITAT (See 'Breaking News')

Govt subsidies worth USD 500 bn to farmers harming markets: OECD Report

I-T - Any addition applying concept of income deemed to be accrued or arise in India can be made when situs of service rendered is abroad: ITAT (See 'Breaking News')

TP - Existence of legally valid draft order is mandatory pre-condition for passing of legally valid DRP proceedings, and legally valid final assessment order: ITAT (See 'Breaking News')

The global spat on digital taxes - A 'variety' of countries v the USA (See 'EDIT')

TP - When assessee has consistently been returning profits for taxation purpose, AO can sit in arm chair of businessman to disallow management fees paid to its AE: ITAT (See 'Breaking News')

TP -If on application of turnover filter, no comparable company would remain for determining ALP, issue of TP adjustment is to be restored to file of AO/TPO for undertaking exercise afresh by selecting fresh set of comparable companies: ITAT (See 'Breaking News')

TP - Two entities are functionally similar for purpose of being treated as comparables to each other, is question of fact & HC need not delve into merits of such aspect, unless findings in this regard are perverse in law: HC (See 'Breaking News')

TP - Mere incurring of AMP expenses can't be considered as international transaction: 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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