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INTL TAXATION INTL MISC TP FDI LIBRARY VISA BIPA NRI
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TP - Assessee's explanations in respect of any amount cannot be discarded, without recording of findings that assessee has any other source of income & which hitherto has not been declared: ITAT (See 'Breaking News') TP - Entity engaged in diversified activities and having incurred significant R&D expenditure and owning intangible assets, cannot be compared to pure ITES provider: ITAT (See 'Breaking News') TP - Entity deriving income from trading activity and also maintaining inventories cannot be considered as good comparable to marketing support service provider: ITAT (See 'Breaking News') I-T - Provisions of Section 206AA are applicable to recipient of income who is covered by DTAA between India and home country of such recipient: ITAT (See 'Breaking News') TP - Expat support reimbursement cannot be treated as duplicative in nature, if taxpayer has earned income from its customers at cost plus markup after including cost of such services: ITAT (See 'Breaking News') TP - It is fit case for remand where MAP resolution is passed much after assessment order being passed by AO: ITAT (See 'Breaking News') Review of Foreign Direct Investment (FDI) Policy in Defence Sector (See 'Bulletin Bord') TP - Functional dissimilarity and ownership over huge intangibles calls for exclusion of comparable: ITAT (See 'Breaking News') TP - RPM cannot be applied for bechmarking international transactions between two AEs, if there are broad differences in functions performed and gross margins earned: ITAT (See 'Breaking News') TP - Final assessment and transfer pricing order along with levy of penalty, passed by AO in garb of draft assessment without complying with mandate of Sec 144C, is invalid: ITAT (See 'Breaking News') TP - High Court's writ jurisdiction cannot be invoked where assessee does not make strong case for waiver of efficacious alternate remedy of appeal: HC (See 'Breaking News') GST - Breezily e-invoicing amidst COVID-19 - Voicing concerns crawling lately! (See 'The Cob(Web)' Column) TP - Merchant banker cannot be compared to entities engaged in providing non-binding investment advisory services, for purposes of benchmarking: ITAT (See 'Breaking News') TP - Where CUP method has consistently been applied in assessee's case over years for benchmarking purposes, adoption of TNMM in current AY is not sustainable: ITAT (See 'Breaking News') TP - Order making TP adjustment is unsustainable where assessee is not given proper opportunity to file reply to Show Cause Notice & order is passed without TPO giving sufficient thought to assessee's replies: HC (See 'Breaking News') TP - Excessive AMP expenditure of taxpayer cannot be treated as international transactions u/s 92B by merely applying BLT method, if such expenses are duly disclosed in Form 3CEB: ITAT (See 'Breaking News') I-T - Payments for acquiring off-shelf software would be in nature of business profits in hands of non-resident if it does not have PE in India: ITAT (See 'Breaking News') TP - Any action u/s 263 can be taken on account of infringement of an omitted provision, particularly when same is not protected by any saving clause: ITAT (See 'Breaking News') TP - An ITE service provider and KPO service provider can be compared for purposes of ALP determination: ITAT (See 'Breaking News')
 
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