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INTL TAXATION INTL MISC TP FDI LIBRARY VISA BIPA NRI
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TP - In absence of segmental information, companies engaged in two different business modules, cannot be adopted as comparables: ITAT (See 'Breaking News') TP - When results for financial year can reasonably be extrapolated, then comparable cannot be excluded solely on ground that they have different financial year endings: ITAT (See 'Breaking News') TP - When TP adjustments suggested by TPO are not in accordance with law and Assessee has also not adopted correct method of benchmarking, such matter calls for restoration: ITAT (See 'Breaking News') TP - No penalty u/s 271G can be levied, if Assessee had complied with directions of TPO and placed on record requisite information to extent same was practically possible: ITAT (See 'Breaking News') DTAA - Any amendment u/s 9(1)(vi) of I-T Act cannot influence definition of 'royalty' as given under respective DTAA: ITAT (See 'Breaking News') I-T - Once telecom company accepts taxability of income received from provisions of telecom services as 'royalty', appeal impugned previously should be dismissed as withdrawn: (See 'Breaking News') Digital economy to the fore again (See 'TII EDIT') Global Forum releases Peer Review Reports on AEOI standards (See 'TII Brief') TP - Income and expenses of only operating nature are to be taken into account for working out Operating Profit of Tested Party from controlled transaction: ITAT (See 'Breaking News') I-T - Mere confirmation of addition in appeal under quantum assessment cannot per se lead to confirmation of penalty: ITAT (See 'Breaking News') DTAA - When Assessee have no business connection in India or Agency PE/Base BE having no no business income, provisions of section 40(a) is not applicable: ITAT (See 'Breaking News') I-T - Assessee cannot be held liable for failure attributable on part of AO in negligency in making enquiries: ITAT (See 'Breaking News') TP - Method of benchmarking and selection of comparables, should not be done merely by quoting judicial pronouncement and without affording opportunity of hearing: ITAT (See 'Breaking News') TP - No ALP adjustment is warranted on international license revenue receivables from AEs: ITAT (See 'Breaking News') TP - Final order of assessment passed by AO on nonexisting entity post order of Writ Court approving Scheme of Amalgamation, is invalid: ITAT (See 'Breaking News') DTAA - Freight income earned by foreign entity from operating ships in international traffic, is not taxable in India, even if feeder vessels are not owned by such company: ITAT (See 'Breaking News')
 
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