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INTL TAXATION INTL MISC TP FDI LIBRARY VISA BIPA NRI
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TP - If loan was provided by third party lender, but AE provides explicit or implicit guarantee to such lender or deposits corresponding amount of funds with lender, such debt shall be deemed to have been issued by AE: ITAT (See Breaking News) TP - Risk adjustment disallowed where no basis is found for granting it, more so, where assessee fails to provide credible evidence to distinguish its risk profile that of the comparable companies: ITAT (See Breaking News) I-T- Jurisdictional issues can be raised at any stage, especially when they go to the root of the matter: ITAT (See Breaking News) I-T - Payments made for marketing related services and use of trademark etc which is incidental to main objective cannot be categorised as royalty or FTS: HC (See Breaking News) I-T - If assessee had filed its objection before DRP, albeit not intimated due to glitches in website, NFAC ought to have awaited outcome of DRP proceedings and could not have proceeded to pass assessment order: HC (See Breaking News) I-T - Not mentioning pendency of writ cannot be construed as failure to disclose material fact, which would render declaration made by assessee non-est u/s 91(5)(a) of Finance (No.2) Act 2024 or otherwise invalid: HC (See Breaking News) TP - Comparable company merits being dropped where it is functionally dissimilar to the assessee and segmental data is lacking: ITAT (See Breaking News) TP - Entity exclusively engaged in ITES segment is not comparable to entity engaged in distribution activities: ITAT (See Breaking News) TP - CUP method shall be applied for benchmarking, in case of comparison between ratio of Intra Group Services payment to sales of assessee with ratio of similar expenses to sales of comparables: ITAT (See Breaking News) I-T - Assessment passed in name of non-existent company is bad in law: ITAT (See Breaking News) I-T - Proceedings u/s 263 cannot be initiated for purpose of making fishing/roving enquiries w.r.t. variety of issues only with objective of substituting his views with that of AO: ITAT (See Breaking News) TP - If assessee is not charging interest on account of delay in receivable either from its AEs or from non-AEs, no adjustment of interest in respect of overdue receivable can be made: ITAT (See Breaking News) TP - Comparable company merits being excluded where its business model differs considerably from that of the assessee & which has a brand value different from that of assessee: ITAT (See Breaking News) DTAA - Merely having PE in India is not sufficient to exclude applicability of Article 11(2) and invoke Article 11(6) r/w Article 7(1) of India-Japan DTAA: ITAT (See Breaking News) I-T - One-time benefit received by retired cricketor from Board of Control for Cricket in India in recognition of his past services to Indian cricket, is eligible for exemption u/s 56(2)(vii) and not subject to tax: ITAT (See Breaking News) TP - Segmented information shall be used for benchmarking trading activity involving purchase of finished goods and manufacturing activity involving purchase of raw materials and export of manufactured goods: ITAT (See Breaking News) Trump's Tariff Tantrums (See 'TII Edit')
 
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About Us

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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