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DTAA - Payment received on account of subscription, professional and training services cannot be deemed to be Fees for Technical service and be t...
I-T- Onus of establishing receipt of services from Associated Enterprise has to be discharged on year to year basis by assessee company: ITAT...
I-T - If assessee is not making available underlying know-how with respect to research projects as enumerated under DTAA & MOU, then receipts und...
TP - If assessee has suo-moto offered guarantee commission and no inherent risk arises to financial services utilized by AE from assessee, then n...
INTL - Expenses incurred by a non-resident individual towards obtaining Special Power of Attorney & anciliary expenses, for purpose of transferri...
TP - ALP adjustment cannot be made with reference to entire turnover of assessee and ought to be restricted to value of international transaction...
TP - Land acquisition matters where market value is determined on bases of certain parameters peculiar to parties & property, CUP method is more ...
TP - Once assessment record is transferred by faceless unit to AO having territorial jurisdiction, then no action u/s 263 is possible with PCIT w...
TP - Not adopting mandatorily prescribed methods to determine ALP in respect of fees of technical services payable by Assessee to its AE, make en...
TP - If any third party rate is not considered for particular date of contract due to non availability of data, would not enable TPO to reject me...
TP - If there is difference between ALP determined by particular method & transfer price adopted by assessee, it may warrant the transfer pricing...
DTAA - As per settled law, consideration for resale/use of computer software through EULA or distribution agreement, is not Royalty for use of co...
DTAA - Therefore, such payment does not give rise to any income which is taxable in India & in which case no TDS is to be deducted u/s 195 of the...
TP- The limitation period does not get extended by virtue of transfer of the case record internally from FAO to JAO: ITAT ...
I-T- The credit available to assessee may be eligible as a refund where consideration on which tax has been deducted is not taxable: ITAT ...
TP - Once Specified Domestic Transactions have been omitted from the I-T Act, then no transfer pricing adjustment can be made in this regard by i...
TP - Explanatory notes to provisions of Finance Act only explain the substance of provisions of concerned Finance Act relating to Direct taxes & ...
TP - Power of revision cannot be invoked in a manner which is contrary to directions issued u/s 119 of I-T Act: ITAT...
I-T-It is in the interest of justice to admit the additional evidence and remand the issue raised relating to disallowance back to AO for denovo ...
I-T- Once the expenses have no nexus with the units eligible for deduction, such expenses can be allocated to units for the purpose of computing ...

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