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NEWS FLASH
 
DTAA - provision of technical services does not per se suffice for consideration for services to qualify as Fees for Included Services: ITAT (See 'Breaking News') DTAA - Make available entails transmitting technical knowledge such that service recipient derives enduring benefit & utilizes such technical knowledge or skill in future without aid from service provider: ITAT (See 'Breaking News') DTAA - That provision of service may require technical input by the person providing the same, it does not per se mean that technical knowledge, skills, is made available to service recipient: ITAT (See 'Breaking News') INTL - Once clinical trial expenses incurred outside approved R&D facilities, are approved by prescribed authority, then assessee is entitled to claim deduction u/s 35(2AB): ITAT (See 'Breaking News') TP - Functional dissimilarity is sufficient for excluding comparables for purposes of benchmarking: HC (See 'Breaking News') TP - Once working capital adjustment is granted to assessee, there is no need for further imputation of interest on outstanding receivables at end of year: HC (See 'Breaking News') INTL - Final assessment order merits being quashed where it is largely a copy of draft assessment order & omits to consider directives given by DRP: ITAT (See 'Breaking News') TP - If TPO fails to answer issue of international transactions bearing in mind Explanation (i)(c) of Section 92B, no addition of arms' length interest is warranted on account of delayed receivables: HC (See 'Breaking News') I-T- For activity of assessee to be in charitable in nature, services rendered must commensurate with benefit that may arise to such poor people : ITAT (See 'Breaking News') I-T - Fees received by the foreign branch of banking company for extending credit line to account holder outside India, would not be taxable in India: HC (See 'Breaking News') TP - Once ALP principle is satisfied, no further profit is attributable even if there is PE in India: HC (See 'Breaking News') TP - Additions on account of Advertising, Marketing & Promotional expenses are unwarranted where no evidence exists to suggest arrangement between Indian assessee & its AE abroad: HC (See 'Breaking News') TP - There is no thumb rule of applicability of LIBOR plus basis points, considering that it depends upon various factors: ITAT (See 'Breaking News') DTAA - India-Ireland treaty exempts aircraft leasing activity from taxation; revenue arising therefrom not treatable as royalty; provisions of DTAA supersede those of I-T Act insofar as they are beneficial to assessee: HC (See 'Breaking News')
 
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TII BREAKING NEWS
 
DTAA - provision of technical services does not per se suffice for consideration for services to qualify as Fees for Included Services: ITAT
DTAA - Make available entails transmitting technical knowledge such that service recipient derives enduring benefit & utilizes such technical knowledge or skill in future without
DTAA - That provision of service may require technical input by the person providing the same, it does not per se mean that technical knowledge,
INTL - Once clinical trial expenses incurred outside approved R&D facilities, are approved by prescribed authority, then assessee is entitled to claim deduction u/s 35(2AB):
< 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 Sep 30, 2024
 
The Delhi High Court decision in the case of Tiger Global - An analysis
By D P Sengupta

TIGER Global - 2024-TII-56-HC-DEL-INTL Management LLC is a US based investment firm founded by Chase Coleman III reputed for spotting and investing in promising start-ups across the globe and exiting at an appropriate time with huge profits. Some of the investments it made were in Alibaba, ByteDance, Coinbase, Facebook, LinkedIn,

 
BULLETIN BOARD
 
New Delhi, Sep 29, 2024
Extension of timelines for filing of various reports of audit for the Assessment Year 2024...
New Delhi, Aug 05, 2024
Non-applicability of higher rate of TDS/TCS as per provisions of section 206AA/206CC of th...
New Delhi, May 27, 2024
Instructions on Money Changing Activities...
New Delhi, May 27, 2024
CBDT notifies RBI u/s 206AB(3)...
< More News >
 
TII BRIEF
 
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 ...
Paris, Sep 12, 2024
GDP growth remain stable in G20 area in Q2: OECD ...
 
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