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DTAA - Provisions do not apply in case of DDT payment u/s 115-O unless specifically extended to domestic company by applicable DTAA: ITAT (See Breaking News) I-T - Money brought in India by non-resident for investment or other purposes is not liable to tax under provisions of Act: ITAT (See Breaking News) I-T - GST should not form part of gross receipts for computing presumptive income u/s 44B: ITAT (See Breaking News) TP - Company which has negative margins and abnormal financial fluctuations is unsuitable for being adopted as comparable company: ITAT (See Breaking News) TP - If TPO himself has accepted TNNM as most appropriate method for determining ALP in subsequent year, then supplementary TP analysis submitted by assessee ought to have been considered for purpose of determining ALP: ITAT (See Breaking News) CBDT expands scope of safe harbour rules (See Brief) TP - If intra-group services utilized by assessee are supporting core activities of assessee, there is no infirmity in assessee adopting TNMM as most appropriate method: ITAT (See Breaking News) TP - Statutory procedure mandated u/s 144C can't be bypassed by merely mentioning name of assessee as amalgamated entity with its former name and name of amalgamating company: ITAT (See Breaking News) I-T - AO must examine if management fees is in nature of FTS or not, before making disallowance of payments made to overseas parties for services rendered by them, which did not have PE in India: ITAT (See Breaking News) Debt markets in Emerging economies grow to USD 3 trillion in 2024: OECD (See Brief) I-T - If necessary requirements to claim benefit of MFN clause does not get satisfied, no treaty benefit can be claimed on dividend income: ITAT (See Breaking News) I-T - Merely because AO has not given elaborate reasoning and findings, does not lead to conclusion that order of AO is erroneous for want of inquiry: ITAT (See Breaking News) TP - In absence of availability of price of electricity in open market, best alternative available with TPO is to benchmark transactions in accordance with computation of ALP as mentioned u/s 92C r.w. Rule 10B: ITAT (See Breaking News) The Trump Card (See TII Edit) TP - For those outstanding receivables that fall out of working capital adjustment pertaining to year under consideration, rate of interest to be charged must be LIBOR + 300 basis points: ITAT (See Breaking News) TP - Reduction for purchase price adjustment can only be done to cost of goods sold/operating cost and not to operating revenue: ITAT (See Breaking News) TP - Merely on assumption of robust research & development facility of assessee with regard to some products developed in India, compensation under technology transfer agreement with non-AE can't be distinguished: 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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