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INTL TAXATION INTL MISC TP FDI LIBRARY VISA BIPA NRI
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I-T - Attribution of revenue to a Permanent Establishment does not limit deduction of expenses incurred to earn that revenue: HC (See Breaking News) I-T - Assessee's statutory right to have objections adjudicated by DRP u/s 144C cannot be defeated by bona fide procedural error, such as filing objections with incorrect AO: HC (See Breaking News) I-T - Where assessee, eligible u/s 144C has filed objections to draft assessment order before DRP, AO cannot lawfully pass final assessment order: HC (See Breaking News) I-T - Authority deciding applications u/s 197 is obligated to decide as per provisions of Income Tax Act, and with due regard to treaties between countries, without being influenced by revenue targets: HC (See Breaking News) I-T - If non-resident's income from mineral oil exploration activities qualifies as FTS or Royalty and is connected to Permanent Establishment in India, it must be taxed u/s 44DA, which overrides Section 44BB: HC (See Breaking News) TP - Failure of TPO to supply copies of agreements that form basis of its findings constitutes violation of principles of natural justice: HC (See Breaking News) Services trade expands modesty in Q4 of OECD Area (See TII Brief) I-T - If operation of airline services is exempt from taxation under relevant DTAA & Income Tax Act, and if there is no outstanding tax demand, competent authority is required to issue NIL certificate u/s 197 for such exempt income: HC (See Breaking News) I-T - Scheme of Section 144C is designed to protect the principles of natural justice and that administrative mechanisms should be put in place to ensure that objections are duly communicated to the AO: HC (See Breaking News) I-T - Objective of Sec 197 is to ensure that where transaction is not taxable, tax is not deducted, thereby protecting assessee's cash flow and preventing Revenue from being burdened with interest on refunds: HC (See Breaking News) DTAA - A Permanent Establishment is to be treated as distinct & separate enterprise & all expenses attributable to it must be allowed, in absence of any specific restriction in DTAA: ITAT (See Breaking News) TP - Time limit for completion of assessment prescribed u/s 153 is definitive outer limit that must be adhered to: ITAT (See Breaking News)
 
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