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TP - Transfer pricing adjustment made on account of corporate charges for technical, marketing and administrative support services availed from its AE, is not tenable where Assessee's transfer pricing study has over a long time been conducted using TNM method: ITAT (See 'Breaking News') SC Ruling in the KRIBHCO case: An Analysis (See 'TII Edit') I-T- According to guidelines issued by CBDT, safe harbour rates would apply only if assessee has opted for them and safe harbour rules don’t have retrospective application: HC (See 'Breaking News') DTAA - When rights to tax certain income, under applicable tax treaty provisions, are allocated to a residence jurisdiction, it is wholly immaterial whether or not source jurisdiction has right to tax said income: ITAT (See 'Breaking News') DTAA - Payment of consideration would be regarded as Fee for technical/Included Services only if the twin test of rendering services and making technical knowledge available at the same time is satisfied: ITAT (See 'Breaking News') TP - As clause (i) of section 92BA stands omitted & omission of such provision is to be construed as if it never existed, then no ALP is required to be determined for transaction with specified persons in section 40A(2)(b) of a domestic transaction: ITAT (See 'Breaking News') I-T - Assessment order issued without mentioning of DIN be treated as invalid: ITAT (See 'Breaking News') TP - It is fit case for remand where foreign exchange fluctuation loss adjustment is to be recomputed by TPO upon considering Profit Level Indicator from relevant details: ITAT (See 'Breaking News') TP - Company adopted as comparable for benchmarking purposes, merits being dropped as comparable, due to absence of data pertaining to its financials: ITAT (See 'Breaking News') I-T - Addition u/s 56(2)(vii)(b) is unwarranted, where difference between actual sale consideration & FMV determined by valuation officer is less than 10%: ITAT (See 'Breaking News') INTL - Evidences obtained from external sources & having critical bearing on outcome of subject matter, ought to have been admitted to reinforce overriding cause of substantial justice vis-a-vis technical considerations: ITAT (See 'Breaking News') INTL - First Appellate Authority is obligated to ensure that an effective opportunity is granted to the assessee for presenting its case and all evidences are taken into account while determining issue at hand: ITAT (See 'Breaking News') DTAA - Broadcasting Reproduction Right is different from copyright as defined in the Copyright Act: ITAT (See 'Breaking News')
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Taxindiainternational.com (“TII”), established on April 23, 2010, is a dedicated portal on international taxation. TII was launched in response to the changing landscape of taxation in India. It happens to be the FIRST comprehensive and exhaustive online resource for the taxpayers and also tax authorities looking for well-arranged resource on Transfer Pricing, Double Taxation Tax Treaties, FDI, FEMA, PMLA, BIPA, NRI and Visa guidelines for various categories of expatriates employed in India by MNEs. 

TII is a sister portal of India’s most prestigious and popular taxation and trade portal Taxindiaonline.com (TIOL). In about to be nine years, TII has carved a niche for its quality, speed and authenticity among domestic as well as international users. It has earned the respect and confidence of many global experts of international taxation. It is a highly reliable resource for the various fora of the Indian judiciary. Its citations are frequently used by the courts in their decisions. Its well-researched articles are regularly referred to by the policy makers in India. Its recommendations are generally respected by the Ministry of Finance in India.

TII has a huge subscriber-base cutting across users community ranging from Foreign Taxation Division in the CBDT, Directorate of Transfer Pricing & International Taxation to advocates, law firms, MNEs, domestic companies and research organisations. It has an enviable team of in-house experts and Consulting Editors who keep an eye on the global trend and keep sensitising the policy makers on the future trends of transforming fiscal world.

Consulting Editor

Mr. D.P. Sengupta: Mr Sengupta, a former member of the IRS, retired as Chief Commissioner of Income Tax after more than 33 years of distinguished service. Before that he had a highly satisfying stint as Joint Secretary in the Tax Policy and Legislation division of the Central Board of Direct Taxes.He also served as Joint Secretary in the Foreign Taxation Division of the Ministry of Finance. He was the Competent Authority for India and represented India in the WP1 of the OECD. He is a well known international taxation expert and spoke at various international tax conferences.

CEO & Managing Editor

Shailendra Kumar, founder and CEO of TIOL started his career with The Indian Express Newspaper in 1990 and then moved to The Economic Times where he worked for more than five years before taking the entrepreneurial route to launch TIOL, an idea based on a business need which he realized as a financial journalist. His vision was to create a knowledge-driven company; which eased the burden on corporations and which acted as a media watchdog for Indian tax and trade policies. He spearheads the business in all of its facets, including regular interactions with various policy makers and administrators, and managing the editorial and news gathering team at TII. He is the recipient of the 2001 Outstanding Media Professional Award presented by the India International Professionals Forum.


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