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TP - Mere non furnishing of information and documents in manner sought by AO cannot lead to automatic levy of penalty u/s 271G: ITAT (See Breaking News) TP- If other method is applied requiring price of uncontrolled transaction with or between non-AEs, provision of Sec 94B can't be imputed into it as it deals with transaction between two AEs: ITAT (See Breaking News) TP - Power of revision u/s 263 cannot be exercised where PCIT failed to demonstrate any non-application of mind or omission by AO that rendered assessment order erroneous: ITAT (See Breaking News) TP - TPO must provide opportunity to assessee to substantiate existence and nature of remibursement expenditure alongwith benefit of such expenditure to assessee: ITAT (See Breaking News) I-T - Reimbursement of client related expenses paid to wholly owned principal company abroad, are not subjected to withholding tax u/s 195: ITAT (See Breaking News) I-T- Expenses, incurred for the welfare of key managerial personnel, qualify as business expenses allowable u/s 37 of the I-T Act, 1961: ITAT (See Breaking News) TP - Amount of receivable from AE and non-AE does not decide credit period given to AE, and question of imputing interest arises only when assessee provides extra credit period to AE: ITAT (See Breaking News) TP - Once foreign travel expenses are included in cost base & recovered from AE with markup, they form part of operating expenses under APA: ITAT (See Breaking News) TP - Absence of segmental data for various streams of revenue calls for exclusion of comparable, if entity was having revenue from multiple service lines: ITAT (See Breaking News) TP - While drawing segmental details, TPO ought to consider revenue of segments and cost that was allocated to respective segments: ITAT (See Breaking News) I-T - DRP proceedings did not contain valid DIN and assessment order also does not contain DIN, then assessment order would be invalid: HC (See Breaking News) I-T- Once assessee had disputed stamp duty valuation & provides credible material including earlier departmental valuation, then AO is obligated under the third proviso to Section 56(2)(x) r/w Section 50C(2) to refer the matter to Valuation Officer: ITAT (See Breaking News) I-T - Consideration for Health Ecotox services did not qualify as FTS under India-Netherlands Tax Treaty, if ‘make available' clause is not satisfied: ITAT (See Breaking News) TP - Functional dissimilarities and impact of extraordinary events like amalgamations, calls for rejection of comparables for purposes of benchmarking: ITAT (See Breaking News) TP - Benchmarking of operating results from international transactions of rendering software development and related services to AEs as well as non-AEs by applying TNMM, can't be disregarded on account of lack of segmental reporting: ITAT (See Breaking News) DTAA - Fabrication charges for bushings were not taxable as FTS under Article 12(4)(a) of India-Singapore DTAA where no technical knowledge or expertise is made available or transferred: ITAT (See Breaking News) OECD to release Tax Inspectors Without Borders' 10-yr Report CBDT notifies Protocol amending India-Oman DTAA TP - Cognizance taken by AO u/s 92CA is invalid, if it has been omitted from statute itself: ITAT (See Breaking News) TP - Internal TNMM is more superior than external TNMM, more so when audited segmental are available: ITAT (See Breaking News) TP - Interest payable on NCDs whivh are denominated in Indian currency is to be benchmarked by applying PLR as against LIBOR: ITAT (See Breaking News)
 
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