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NEWS FLASH
 
TP - Functional dissimilarity is enough ground for rejection of comparable: ITAT (See 'Breaking News') TP - e-connectivity charges paid by assessee-company to its parent company abroad is allowed as revenue expenses & on which deduction is allowed: ITAT (See 'Breaking News') Post-COVID-19 - New World Order - 'Chini Kum' if eye is on rule-based stability! (See 'The Cob(Web) Column') I-T : Provision of Guarantee fees service is not fee for Technical services under India - Netherlands DTAA: ITAT (See 'Breaking News') TP - In terms of rule 10B(l)(e)(i), any addition can be made on notional basis, whether cost incurred by AE can be added financial statement of assessee: ITAT (See 'Breaking News') I-T - Depreciation is allowed in respect of such expenses: ITAT (See 'Breaking News') TP - Consistent method followed & accepted in transfer pricing proceedings, can be changed without there being any change in facts or law: ITAT (See 'Breaking News') Govt subsidies worth USD 500 bn to farmers harming markets: OECD Report I-T - Any addition applying concept of income deemed to be accrued or arise in India can be made when situs of service rendered is abroad: ITAT (See 'Breaking News') TP - Existence of legally valid draft order is mandatory pre-condition for passing of legally valid DRP proceedings, and legally valid final assessment order: ITAT (See 'Breaking News') The global spat on digital taxes - A 'variety' of countries v the USA (See 'EDIT') TP - When assessee has consistently been returning profits for taxation purpose, AO can sit in arm chair of businessman to disallow management fees paid to its AE: ITAT (See 'Breaking News') TP -If on application of turnover filter, no comparable company would remain for determining ALP, issue of TP adjustment is to be restored to file of AO/TPO for undertaking exercise afresh by selecting fresh set of comparable companies: ITAT (See 'Breaking News') TP - Two entities are functionally similar for purpose of being treated as comparables to each other, is question of fact & HC need not delve into merits of such aspect, unless findings in this regard are perverse in law: HC (See 'Breaking News') TP - Mere incurring of AMP expenses can't be considered as international transaction: ITAT (See 'Breaking News')
 
 
 
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TII BREAKING NEWS
 
TP - Functional dissimilarity is enough ground for rejection of comparable: ITAT
TP - e-connectivity charges paid by assessee-company to its parent company abroad is allowed as revenue expenses & on which deduction is allowed: ITAT
TP - In terms of rule 10B(l)(e)(i), any addition can be made on notional basis, whether cost incurred by AE can be added financial statement
I-T : Provision of Guarantee fees service is not fee for Technical services under India - Netherlands DTAA: ITAT
< More News >
 
TII SPECIAL Jun 24, 2020
 
Captive concerns - whether negative working capital adjustment required in TP proceedings?
By S Ramanujam

Introduction :

DURING the year 2001, guided by the international tax models, with a view to expanding the tax base, the Government brought in new provisions in Chapter X under the heading - Special Provisions Relating to Avoidance of Income Tax - commonly referred to as Transfer Pricing (TP) provisions. The main

 
TII EDIT Jun 29, 2020
 
The global spat on digital taxes - A 'variety' of countries v the USA
By D P Sengupta

IT is ironic that the USA that exposed the tax games played by its own multinationals in the famous senate Permanent Sub-committee hearings in 2013, has now officially walked out of the most contentious of the OECD-led BEPS action plan 1 -addressing tax challenges of the digital economy. According to Financial Times, Steven

 
BULLETIN BOARD
 
New Delhi, Jun 02, 2020
Govt amends Passport Rules 1980; Fee can be paid online or in cash at counter ...
New Delhi, May 27, 2020
Income tax - Sec 9A - Rule 10V - Sub-rule (10) & forms notified in relation to remunerati...
New Delhi, May 22, 2020
Calling for applications for posting of IRS officers to the post of First Secretary in the...
New Delhi, May 20, 2020
TP - Rule 10 - CBDT notifies amendments w.e.f April 1, 2020...
< More News >
 
TII BRIEF
 
New Delhi, Jul 03, 2020
Fight against tax evasion - 84 mn offshore accounts data shared in 2019: OECD ...
New Delhi, Jun 30, 2020
Govt subsidies worth USD 500 bn to farmers harming markets: OECD Report...
Paris, Jun 12, 2020
G20 Area GDP dips by 3.4% in Q1 - highest since 1998 ...
Paris, Jun 11, 2020
Impact of lockdown in Europe is harsher: OECD ...
New Delhi, Jun 03, 2020
Trump formally invites PM to G-7 Summit...
 
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