Thursday , June 22, 2017 |   03:44:14 IST
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NEWS FLASH
 
GST - July 1 - Another 'Disruptive' Decision? (See 'THE COB(WEB)' in TIOL) TP - DRP can confirm, reduce or enhance variations proposed in draft order but is not empowered to remit issue back to AO/TPO u/s 144C(5): ITAT (See 'Breaking News') TP - ALP of 'management services fee' can be determined at Nil, in absence of any actual rendering of services by AE: ITAT (See 'Breaking News') TP - Armís length commission of 3.63% is appropriate rate of ALP for benchmarking 'Direct Sales Compensation' in hands of assessee: ITAT (See 'Breaking News') TP - Once assessee has raised objection with respect to functional data, employee cost & application of RPT filters, it is DRP's duty to examine them: ITAT (See 'Breaking News') DTAA - Payment for supply of software, can't be treated as 'royalty', if the payment was not for 'copyright along with secret code for creating multiple software copies': ITAT (See 'Breaking News') I-T - Payment made to non resident entity on account of outright sale cannot be termed as royalty or fee for technical services: HC (See 'Breaking News') CBDT inserts new columns in Form No 3CED (See 'Notificaiton' in TP) Repatriation of excess money with AEs: Rule to apply to primary adjustments exceeding Rs 1 cr (See 'TII Brief') TP - Tribunal not to interfere in matters concerning royalty & suppressed sale of scrap if same have been dealt with in detail by CIT(A): ITAT (See 'Breaking News') TP - Deduction u/s 10B is available only to EOU's approved by Board appointed by Central Government - ITAT (See 'Breaking News') Mr Shibanka Biswas, IRS, posted as DCIT (OSD) in FT&TR-III(1) Division (See 'Administrative Order' in Intl Taxation) TP - When advances are made to company situated abroad then arms length interest will be determined by applying LIBOR rate: HC (See 'Breaking News') TP - HC admits appeal relating to penalty u/s 271(1)(c) & addition made under Chapter X among others: HC (See 'Breaking News') TP - Dismissal of objection filed before DRP & communication thereof to be treated as direction given to AO to complete the assessment as per draft order: HC (See 'Breaking News') TP - Grounds not agitated before lower authorities & being questions of fact, cannot be raised as substantial questions of law before HC: HC (See 'Breaking News') CBDT notifies Rule 10CB relating to time limit for repatriation of excess money u/s 92CE (See 'Notification 52/2017' in 'TP')
 
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TII BREAKING NEWS
 
TP - DRP can confirm, reduce or enhance variations proposed in draft order but is not empowered to remit issue back to AO/TPO u/s 144C(5):
TP - ALP of 'management services fee' can be determined at Nil, in absence of any actual rendering of services by AE: ITAT
TP - Armís length commission of 3.63% is appropriate rate of ALP for benchmarking 'Direct Sales Compensation' in hands of assessee: ITAT
TP - Once assessee has raised objection with respect to functional data, employee cost & application of RPT filters, it is DRP's duty to
< More News >
 
TII SPECIAL Jun 16, 2017
 
Safe Harbour Rules - Is it safe?
By Vikas Gupta, Tamojit Lodh & Arvind Agarwal

IN the year 2013, the CBDT had introduced the Safe Harbour Rules ('SHR'), optional for a taxpayer, with the conditions and circumstances under which norms / operating margins would be accepted for certain categories of international transactions by the tax authorities. The safe harbour margins are akin to an arm's

 
TII EDIT May 22, 2017
 
Tax treaty interpretation - Perspectives from some Asian Countries
By D P Sengupta

THE conference on tax treaty case laws around the globe took place in Vienna this year. As in earlier years, the most important case laws decided in different parts of the world were discussed. It is quite fascinating to observe the differing attitudes of the tax administrations and the tax courts in different parts

 
BULLETIN BOARD
 
New Delhi, Jun 15, 2017
CBDT notifies Rule 10CB relating to time limit for repatriation of excess money u/s 92CE...
New Delhi, Jun 09, 2017
ALP margin - CBDT notifies 1% for wholesale and 3% for other cases ...
New Delhi, Apr 17, 2017
CBDT creates 13 posts of CIT (DR) & (DRP) by diverting posts of CIT(A)...
New Delhi, Apr 11, 2017
CBDT issues clarification with respect to seafarer receiving remuneration in NRE account...
< More News >
 
TII BRIEF
 
New Delhi, Jun 19, 2017
Repatriation of excess money with AEs: Rule to apply to primary adjustments exceeding Rs 1...
New Delhi, Jun 15, 2017
Foreign Co as Indian resident - CBDT seeks suggestions on Draft Notification...
New Delhi, Jun 08, 2017
CBDT notifies New Safe Harbour Regime to reduce disputes...
Paris, Jun 08, 2017
76 tax jurisdictions sign BEPS Convention; 1100 tax treaties to be amended worldwide ...
Paris, Jun 06, 2017
BEPS Convention to be signed on June 7...
 
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