FDI rises 15% in April-September to USD 30billion - Taxindiainternational.com

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India-Brazil revamped tax treaty (See TII Edit)

TP – No ALP is to be made on outstanding receivables in absence of any inter-company agreement or email correspondence between AES: ITAT (See Breaking News)

I-T - Mere grant of stay or pendency of further proceedings does not obliterate existence or binding nature of judgment unless it is set aside: ITAT (See Breaking News)

TP - Functional dissimilarity and variation in business segment calls for exclusion of comparable: ITAT (See Breaking News)

TP - DRP process forms part of assessment proceedings and does not displace outer limitation prescribed by section 153: ITAT (See Breaking News)

TP – If comparable is already accepted by TPO and such acceptance is upheld by CIT (A), then Revenue cannot seek its exclusion on ground that it is functionally not comparable: ITAT (See Breaking News)

I-T - Buy-back amounted to transfer of shares within same corporate group and qualified as corporate reorganization under Article 13(5) of Indo Netherland Treaty: ITAT (See Breaking News)

I-T – If borrowed funds are used for expansion or extension of business, including through acquisition of entity in same line of business, interest may be allowable u/s 36(1)(iii): ITAT (See Breaking News)

I-T - Sections 144C and 153 are mutually inclusive and period of limitation for passing final assessment order u/s 144C(13) has to be determined with reference to sec 144C r/w/s 153: ITAT (See Breaking News)

DTAA - Benefit of FTC u/s 90 r/w applicable DTAA cannot be denied merely on account of delay in filing Form 67 when taxes have actually been paid abroad: ITAT (See Breaking News)

I-T - Sections 144C & 153 are inter-dependent; overall time limit prescribed u/s 153 applies to completion of entire assessment, including DRP proceedings & passing of final assessment order: ITAT (See Breaking News)

I-T - Time-limit prescribed u/s 153 has to be adhered to and both Section 144C and 153 are mutually inclusive & interdependent: ITAT (See Breaking News)

I-T - If notice issued by AO u/s 148 is barred by limitation as per mandate of ‘first proviso' to Sec 149, consequential assessment order passed on basis of same u/s 147 r.w.s 144 is to be quashed: ITAT (See Breaking News)

DTAA - Collating & providing access to information already available in public domain databases relating to properties situated in US does not entail transfer of specialised commercial experiece, know-how or technical expertise; fee received therefor not Royalty: ITAT (See Breaking News)

DTAA - Income from technical handling services is not taxable in India as it is covered under Art 8(2) r/w Art 8(1) of Indo France Treaty: ITAT (See Breaking News)

Real household income grows in Q4 in OECD area (See TII Brief)

TP - Amortization of goodwill arising out of merger & acquisition is extraordinary, non-recurring item not arising from normal business operations; cannot be treated as an operating expense for computation ofprofit level indicator: ITAT (See Breaking News)

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FDI rises 15% in April-September to USD 30billion By TII News Services Nov 28, 2020 , New Delhi
Global investors preferred India's enabling environment, as foreign direct investment (FDI) into the country grew by 15% to USD 30 billion during the first half of the current fiscal compared to the same time period last year, according to government data released today. The Department for Promotion of Industry and Internal Trade (DPIIT) noted that FDI into India had also doubled to USD 28.2 billion in the July-September quarter from USD 14.06 billion in the same period last year. “Despite COVID, FDI doubles year-on-year. Indicating global investors' preference for India's enabling environment under Prime Minister [Mr] Narendra Modiji, ” tweeted Commerce and Industry Minister, Mr Piyush Goyal. In July, India attracted USD 17.5 billion worth of foreign investments. Sectors which attracted maximum foreign inflows during April-September 2020-21 were computer software and hardware (USD 17.55 billion), services (USD 2.25 billion), trading (USD 949 million), chemicals (USD 437 million) and automobile (USD 417 million). Singapore was the top destination for FDI equity inflow during the period, with USD 8.3 billion investments. This was followed by the U.S. (USD 7.12 billion), Cayman Islands (USD 2.1 billion), Mauritius (USD 2 billion), the Netherlands (USD 1.49 billion), UK (USD 1.35 billion), France (USD 1.13 billion) and Japan (USD 653 million). FDI is a major driver of economic growth in the country with states such as Gujarat (USD 18.59 billion), Maharashtra (USD 10.88 billion) and Karnataka (USD 7.94 billion) attracting the highest equity inflows.

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