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OECD area employment dips in Q1 (See 'Brief') EU Court nixes USD 15 bn tax order against Apple Post-COVID-19: New Cold War in the making! China to play role of Rogue State Actor! (See 'The Cob(Web)' Column) TP - If there is no change in function of assessee company in relevant year, relying on the order of Coordinate bench of Tribunal in assessee's own case for AY 2008-09 and 2011-12, Infosys Technologies Ltd can be excluded from set of comparables: ITAT (See 'Breaking News') TP - Fluctuation in margins and differences in revenue recognition model, calls for exclusion of comparable: ITAT (See 'Breakine News') I-T - If foreign entity has not provided entire correspondence regarding services rendered to Indian entity, then it is improper for I-T Authorities to decide characterstic of such services: ITAT (See 'Breaking News') TP - Entire AMP expenses cannot be booked as 'international transaction', in absence of any arrangement with AEs for incurring AMP expenses to promote their brand: ITAT (See 'Breaking News') TP - ALP of intra group services cannot be determined at NIL without establishing that services received from AE are duplicate in nature or any tangible benefits has accrued: ITAT (See 'Breaking News') TP - If taxpayer has not charged any interest on delay in receipt of receivables against services rendered to unrelated party, then no notional interest is chargeable in respect of delay in receipt of outstanding receivables from AE: ITAT (See 'Breaking News') TP - Comparable which fails on functional yard stick is not includable: ITAT (See 'Breaking News') I-T - If disallowance u/s 40(a)(ia) goes to enhance profits that are eligible for deduction under Chapter VIA, then deduction under Chapter VIA should be allowed on such enhanced profit: ITAT (See 'Breaking News') TP - Stay on recovery of duty demand merits being allowed where Revenue has already adjusted 25% of outstanding demand, conditional upon assessee not seeking undue adjournment: ITAT (See 'Breaking News') TP - It is imperative for TPO to analyse cost base of comparables, segmental details and benchmarking process, before arriving at any categorical finding regarding appropriate method: ITAT (See 'Breaking News') TP - Commerciality of entering into licensing arrangement and payment of royalty in terms of such an arrangement, merits examination before deciding ALP rate of royalty: ITAT (See 'Breaking News') I-T - in absence of contrary being proved and following order passed by Tribunal previously in assessee's own case Liaison Office does not constitute PE in India: ITAT (See 'Breaking News') CLI remains close to crisis low in India: OECD (See 'Brief') If second wave of COVID-19 hits American economy to grow only by 1.9% in 2021: OECD (See 'Brief')
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