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NEWS FLASH   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')   TII SEARCH   Case Laws Circular/Notification/Instruction DTAA News Social Secuirity Agreement   Home >> INTL MISC>> Draft Guidelines   Intl Misc Draft Guidelines Page 1 Page 2  Draft notification proposing an amendment to rule 44E, Form 34C, 34D and 34DA as per BEPS action item 5, for improving transparency in relation to tax rulings� comments and suggestions-reg. Draft Notification under section 115JG (1) of the Income-tax Act, 1961 in respect of conversion of Indian branch of foreign bank into Indian subsidiary company Manner of determination of fair market values and reporting requirement for Indian concern-Indirect transfer provisions-section 9(1) of the Income-tax Act, 1961-Draft Rules-reg Draft rules for granting relief or deduction of Income-tax under section 90/ 90A/ 91 of the Income-tax Act CBDT releases Draft Guiding Principles for determination of POEM

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 Portion of I-T Rules,1962 Instructions Administrative Orders DRP Panel I-T Act, 1961 MLI Relevant Portion of I-T Act,1922 GAAR OECD Conventions Draft Guidelines DTC Bill Committee Reports FATCA Intl-Taxation Finance Acts Manual on EoI UN Model 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 Book Review 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 © 2010-2019 Taxindiainternational.com Pvt.Ltd. All rights reserved. TIOL GROUP WEBSITES