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Treaty-shopping: Nepal ejects Mauritius out of its cart (See TII Edit)

TP - Resale price method is most appropriate for benchmarking international transaction in its distribution segment: ITAT (See Breaking News)

TP - CIT(A) ought not to have restored matter back to AO under mistaken view that it was ex-parte order: ITAT (See Breaking News)

I-T - 'Test of imparting' is touchstone if foreign entity continues to use its own industrial and commercial experience to render services, and essence of royalty lies in alienation, not in application: ITAT (See Breaking News)

I-T - Reimbursements of expenses made on cost to cost basis, i.e. without any markup, cannot be treated as FIS, in absence of make available clause: ITAT (See Breaking News)

I-T - No attribution of profit can be made to PE when there is no existence of PE at all: ITAT (See Breaking News)

I-T - Payments made for providing standard facility for data processing without any human intervention, is not taxable in India as FTS in terms of Sec 9(1)(vii): ITAT (See Breaking News)

I-T - Receipts from distribution activity is not royalty in absence of dependent agent PE: ITAT (See Breaking News)

TP - If there was no value addition, and assessee only sought reimbursement of expenses on cost to cost basis, no ALP adjustment is permitted on account of same: ITAT (See Breaking News)

DTAA - Concepts like virtual PE or Significant Economic Presence, while reflecting evolving international taxation trends, cannot be judicially read into a DTAA, absent express amendment: HC (See Breaking News)

DTAA - OECD materials and practices of other jurisdictions are not relevant against clear language in relevant DTAA: HC (See Breaking News)

I-T - Mismatches in limbs of provisions of section 271(1)(c) renders levy of penalty invalid: ITAT (See Breaking News)

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