Wednesday , November 20, 2024 |   04:11:20 IST
INTL TAXATION INTL MISC TP FDI LIBRARY VISA BIPA NRI
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NEWS FLASH
 
DTAA - Fee received for providing technical non-invasive inspection & integrity assessment services for offshore pipelines, cannot be taxed as Fees for Technical Services, considering that Make Available requirement is not satisfied in this case: ITAT (See 'Breaking News') INTL -Income of a non-resident assessee cannot be taxed in India where such person is employed abroad during relevant period: ITAT (See 'Breaking News') I-T - Receipts from supply of software products cannot be taxed as royalty or FIS, in absence of transfer of any technical know-how with those products: ITAT (See 'Breaking News') I-T - It is wholly inequitable for Department to give short credit to tax duly deducted and deposited based on claim that may be made in return of income: HC (See 'Breaking News') I-T - Bandwidth charges remitted to telecom service providers cannot be treated as royalty either under treaty provisions or u/s 9(1)(vi) of Income tax Act, and hence does not attract TDS: ITAT (See 'Breaking News') DTAA - Notion that enduring benefit gained by client through repairs & maintenance is akin to make available, is incorrect: ITAT (See 'Breaking News') DTAA - Providing customer-based information & guidance does not entail problem solving skills or operations or knowledge which allows recipient to perform services independently in future; consideration therefor not treatable as FTS: ITAT (See 'Breaking News') INTL - Revisionary order passed u/s 263 is invalid, where assessee is not given opportunity to contest the allegations levelled by the CIT: HC (See 'Breaking News') INTL - Buyback transactions would not be treated as transfer for capital gains purposes; power of revision is unwarrantedly exercised where it is based on a hypothetical assumption of facts: ITAT (See 'Breaking News') TP - Resale Price Method for benchamarking purposes is appropriate for assessee-company whose activities are limited to purchasing & reselling products without adding any value & which is consistent with those of a routine distributor: HC (See 'Breaking News') I-T - Payments made overseas for general support services, for which no technology was made available, cannot be taxed as 'FTS': ITAT (See 'Breaking News') I-T - If purported reasons that prompted AO to reassess and disallow DAP expenditure incurred on production, only demonstrate change of opinion on part of AO, then same can't form basis of reopening: HC (See 'Breaking News') INTL - Re-assessment proceedings invalidated where based on erroneous information & where commenced in a mechanical manner & without due application of mind: ITAT (See 'Breaking News') TP - AO could not have assumed jurisdiction u/s 147 based on audit objections after expiry of four years from relevant A.Y: HC (See 'Breaking News') INTL - Additions framed u/s 69 are invalid where assessee substantiates nature & source of investment & thus discharges onus of proof: ITAT (See 'Breaking News') DTAA - Comparable company merits being excluded where it operates with extraordinary margins & diverse business interests, including intangibles in contrast to assessee-company: ITAT (See 'Breaking News') TP - As is trite law, transfer pricing adjustment has to be done only in respect of international transactions with associated enterprises & not at entity level: ITAT (See 'Breaking News') DTAA - Payments made by Google India Pvt Ltd. to Google Ireland Limited (GIL) for the Adwords program are not in the nature of royalty or FTS & therefore, cannot be taxed in the hands of assessee: ITAT (See 'Breaking News') TP - No separate ALP adjustment is required for payment of royalty if TNMM approach has been adopted at entity level: ITAT (See 'Breaking News')
 
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TII BREAKING NEWS
 
DTAA - Fee received for providing technical non-invasive inspection & integrity assessment services for offshore pipelines, cannot be taxed as Fees for Technical Services, considering
INTL -Income of a non-resident assessee cannot be taxed in India where such person is employed abroad during relevant period: ITAT
I-T - Receipts from supply of software products cannot be taxed as royalty or FIS, in absence of transfer of any technical know-how with those
I-T - It is wholly inequitable for Department to give short credit to tax duly deducted and deposited based on claim that may be made
< More News >
 
TII SPECIAL Jun 24, 2024
 
A peep into Global Tax Reforms Architecture
By Pratap Singh, Principal CIT

 

THIS article aims to present an overview of the global tax reforms underway, exploring its challenges, key initiatives, and potential outcomes. It explores the importance of international cooperation under UN/G20/OECD, in addressing tax avoidance and ensuring that businesses contribute their fair share to the societies in which they operate.

 
TII EDIT Oct 28, 2024
 
Attribution of Profit to a Permanent Establishment when globally the enterprise is in a loss
By D P Sengupta

THERE are two hurdles in taxing the cross-border income of multinational enterprises in a source country, in terms of the rules of the game that were laid down more than a century back and that, despite the recent turmoil in the field of international taxation, still governs the field.

As

 
BULLETIN BOARD
 
New Delhi, Nov 04, 2024
Order under section 119(1) of the Income-tax Act, 1961 fixing monetary limits of the incom...
New Delhi, Oct 30, 2024
Condonation of delay under clause (b) of sub-section (2) of section 119 of the Income-tax ...
New Delhi, Oct 26, 2024
Extension of due date for furnishing return of income for the Assessment Year 2024-25...
New Delhi, Oct 15, 2024
Guidance Note 1/2024 on provisions of the Direct Tax Vivad se Vishwas Scheme, 2024...
< More News >
 
TII BRIEF
 
Paris, Oct 29, 2024
Better design of tobacco taxation needed to reduce consumption in Latin America: OECD ...
Paris, Oct 01, 2024
Declining trend of taxation is now staging a reversal: OECD...
Paris, Sep 25, 2024
Global economy turning corner as growth remains resilient: OECD ...
Paris, Sep 20, 2024
9 tax jurisdictions ink new treaty to implement Pillar 2 ...
Paris, Sep 17, 2024
Pillar 1- Multilateral tax treaty to be signed on Thursday ...
 
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