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INTL TAXATION INTL MISC TP LIBRARY VISA BIPA NRI
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TP - Adjustments are to be added to unadjusted operating margin of comparables to identify margin compared would have earned had it been operating with similar working capital position as tested party: ITAT (See 'Breaking News') TP - Loss making comparables that satisfy comparability analysis should not be rejected on sole basis that they suffer losses: ITAT (See 'Breaking News') TP - Government companies are generally unfit for purposes of comparison against private companies driven by profit motive: ITAT (See 'Breaking News') Carbon taxes to help generate more revenue: IMF chief (See 'Brief') TP - TPO should adopt portfolio approach to take both prices that are favourable as well as adverse, in case there is fluctuation in price of same product: ITAT (See 'Breaking News') TP - Disposal of objections by passing of speaking order is indispensable, before passing re assessment order: HC (See 'Breaking News') TP - Investment advisory company should not be compared to merchant banker for purposes of benchmarking: ITAT (See 'Breaking News') I-T - Managerial fees paid overseas without making available any technical knowhow to recipient, does not amount to 'FTS/Royalty' and hence does not attract withholding tax liability: ITAT (See 'Breaking News') EU officially removes Switzerland from blacklist of tax havens Indian GST - Flaw in Design - 'Hurricane Katrina' in the making! (See 'The Cob(Web)' in TIOL) TP - ALP of support services can be determined at NIL, if cost allocation between AEs was on 'Per user' basis without any mark up: ITAT (See 'Breaking News') TP - LIBOR rates should be adopted to benchmark receipt of interest from overseas AEs on advances made to them: ITAT (See 'Breaking News') TP - 'Quantum of expenditure' & 'bright line test' are no basis to conclude 'AMP expenditure' within meaning of 'international transaction' u/s 92B: ITAT (See 'Breaking News') I-T - Revenue once having accepted that non-resident service providers did not receive any income in view of respective DTAA, the occasion to deduct tax at source would not arise: ITAT (See 'Breaking News') TP - Mere fact that taxpayer entity had included an entity in list of comparables, would not bar them from contending otherwise before TPO: HC (See 'Breaking News') TP - Adoption of comparables without any proper reasoning and cryptic order, calls for re-adjudication: ITAT (See 'Breaking News') TP - No penalty u/s 271G is imposable, if peculiar nature of product & constant mixing of diamonds obtained from AEs & non-AEs, renders it difficult to determine segmental profitability to work out internal TNMM: ITAT (See 'Breaking News')
 
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