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TP - If monthly fees are paid to AEs employee based on consultancy agreement, then ALP needs to be apportioned in assessee's hands on account of consultancy charges: ITAT (See 'Breaking News')

https://taxindiainternational.com/case_lawDesc.php?qwer43fcxzt=MTQ0NjA=

I-T - When very same Authorized Representative who appeared before AO in draft assessment proceedings has signed objections in prescribed Form 35A, then same is curable defect u/s 292B: ITAT (See 'Breaking News')

I-T - GST cannot be included while computing deemed income u/s 44B: ITAT (See 'Breaking News')

'Budget of Labour' by female Chancellor in 800 years - A peep into contours of provisions (See 'TII Edit')

I-T - Revenue earned through transporting passengers using third party airlines, under code sharing arrangement, has direct nexus with main business of operation of aircrafts, and hence eligible to treaty benefit: ITAT (See 'Breaking News')

I-T - Method consistently followed by AO should be applied for computing attribution of profit to PE in India in consequtive assessment years: ITAT (See 'Breaking News')

TP - Comparable companies are rightly excluded for benchmarking purposes, where they are functionally dis-similar with also differences in assets & risk appetite: ITAT (See 'Breaking News')

TP - Issue of transfer pricing adjustment in relation to international transaction of royalty payment to AEs, merits status quo, in case of identical facts & circumstances in subsequent years: ITAT (See 'Breaking News')

I-T - It is not open to PCIT to exercise revisionary jurisdiction, unless AO is found to have failed to make inquiries/ verification, which should have been made as per law but were not made: ITAT (See 'Breaking News')

I-T - Final assessment order is valid when the Assessing Officer failed to issue a draft order as required u/s 144C(1) of I-T Act before making final order: ITAT (See 'Breaking News')

I-T- FPI would be entitled to treaty benefits and would not be liable to capital gains tax in respect of sale of shares that were acquired prior to Apr 01, 2017: ITAT (See 'Breaking News')

I-T - When heading is mentioned in order as draft order u/s 144C as result of inadvertent systemic error, same may be read as assessment order u/s 143(3): HC (See 'Breaking News')

I-T - Functional similarity is sufficient for inclusion/ exclusion as comparable entity for benchmarking ALP of international transactions: HC (See 'Breaking News')

TP - Only principle chief commissioner/ chief commissioner/ commissioner can exercise revisionary authority in respect of orders passed by TPO under their command & control: ITAT (See 'Breaking News')

I-T - When AO is not sure if seized document reveal any undisclosed income of assessee and when he has expressed that assessee is merely pass-through entity, then he can't assume jurisdiction u/s 153C: ITAT (See 'Breaking News')

I-T - Receipts from offshore supply to Indian entity are not taxable u/s 44BBB in hands of foreign supplier, in absence of its business connection in India: ITAT(See 'Breaking News')

I-T - Business receipts of an entity which did not have any dependent agent PE in India, cannot be brought to tax in India: ITAT (See 'Breaking News')

TP - High cost for services rendered for implementing a software does raise doubts, but mere suspicion is no basis for holding that no services were rendered by AE for said purpose: ITAT (See 'Breaking News')

TP - Companies which are distinct from assessee on account of high turnover, functional dis-similarity & difference in working capital merit being excluded as comparables for benchmarking purposes: ITAT (See 'Breaking News')

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