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INTL TAXATION INTL MISC TP FDI LIBRARY VISA BIPA NRI
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I-T - Time limit imposed by provisions of Sec 153(2A) would come into force even if part order is remanded to AO: HC (See 'Breaking News') Taxation of Indirect transfer- India was right after all (See 'TII EDIT') TP - TNMM is most appropriate method for benchmarking international transactions which did not involve transfer of unique intangibles: ITAT (See 'Breaking New's) TP - Huge profit / turnover is no ground for exclusion of comparable, unless such difference materially affects cost: ITAT (See 'Breaking News') DTAA - Salary paid to expatriates working in India exclusively for PE of foreign entity in India, will not be covered by Section 44C: ITAT (See 'BreakingNews) I-T - Assessee's books should not be rejected, if it has fulfilled all requirements of Section 44BBB(2) and also had past experience to estimate total cost of turnkey projects: HC (See 'Breaking News') GST - Ground-level problems crying for solutions! (See 'THE COB(WEB)' in TIOL) TP - TPO cannot determine value of management services rendered by AEs to Rs Nil, without applying any transfer pricing methods: ITAT (See 'Breaking News') TP - No addition to ALP can be made, where weighted average margin of comparables is within 5% of margin shown by assessee: ITAT (See 'Breaking News') I-T - When no income has accrued or deemed to be accrued in India to foreign entity, no inference can be drawn that such entity has business connection in India: ITAT (See 'Breaking News') DTAA - Consideration received by non-resident entity from sale of 'standard software', would amount to 'business income' and not royalty: HC (See 'Breaking News') I-T - Profits relating to services rendered by foreign entity, no matter rendered within India or outside India in respect of Indian projects, are taxable in India: ITAT (See 'Breaking News') DTAA - Disallowance of 50% of management charges paid by UK entity is not justified when term 'managerial' is missing in definition of FTS under India-UK DTAA: ITAT (See 'Breaking News') TP - Companies accepted by both Assessee & Revenue as functionally comparable, should first be included in list of comparables: ITAT (See 'Breaking News') TP - In absence of change in circumstantial facts, Assessee's computation of ALP with regard to purchase of capital assets, deserves to be accepted in subsequent A.Ys: ITAT (See 'Breaking News') DTAA - Offshore revenue from supply of non-transferable software, is not taxable as 'royalty', either under I-T Act or DTAA provisions: ITAT (See 'Breaking News') I-T - Contract of sale taking place offshore, cannot be taxed in India: HC (See Breaking News') Auto exchange of tax information - 49 jurisdictions to activate services this month (See 'TII Brief') I-T - When assessee is a mere distributor with no proprietory rights of products, payments remitted to non-resident company cannot be treated as royalty: ITAT (See 'Breaking News') I-T - Non mentioning of specific issues of Assessee in its order, shows failure of ITAT to address them, if they were raised in memo of appeals: HC (See 'Breaking News') I-T - Interest expenses incurred in relation to ECBs, availed for acquiring fixed assets for continuation of existing business, deserve to be allowed: ITAT (See 'Breaking News')
 
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