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TP - Entity which undertakes R&D activities and own intellectual property in form of technology and brand, cannot be compared with software developer: ITAT (See Breaking News) DTAA - Capital loss incurred under I-T Act r/w Art 13(5) of India-Ireland DTAA can't be set off against short term capital gain derived from sale of rights of entitlement: ITAT (See Breaking News) TP - AO must provide opportunity of hearing to assessee before transfering his case to TPO, if there is potential of income arising on determination of ALP of international transaction/ specified domestic transaction: HC (See Breaking News) TP - Comparable company be dropped, where a prior order recalling the inclusion of this company is final and binding: ITAT (See Breaking News) TP - If ITAT has rightly decided ground pertaining to upward adjustment of international transaction of payment of guarantee fees to AE in favour of Assessee, no writ interference is warranted: HC (See Breaking News) I-T- Re-assessment proceedings are invalid where reasons recorded by AO are issued after issuing re-assessment notice: ITAT (See Breaking News) I-T - Role of remitter banker is simply to follow extant procedure and to deduct Tax at source as prescribed under statute: ITAT (See Breaking News) I-T - If payroll of assessee is in India during assignment period but entire salary reported in Form No.16 is cross charged to Singapore entity, then AO must examine no.of days assessee had worked in India before deciding its taxability: ITAT (See Breaking News) I-T - If assessee is not having any PE in India and is covered by India US DTAA and MOA, nature of services rendered by assessee on account of which received remunerations can't be described as FIS: ITAT (See Breaking News)
 
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TP - Entity which undertakes R&D activities and own intellectual property in form of technology and brand, cannot be compared with software devel...
DTAA - Capital loss incurred under I-T Act r/w Art 13(5) of India-Ireland DTAA can't be set off against short term capital gain derived from sale...
TP - If ITAT has rightly decided ground pertaining to upward adjustment of international transaction of payment of guarantee fees to AE in favour...
TP - AO must provide opportunity of hearing to assessee before transfering his case to TPO, if there is potential of income arising on determinat...
TP - Comparable company be dropped, where a prior order recalling the inclusion of this company is final and binding: ITAT ...
I-T- Re-assessment proceedings are invalid where reasons recorded by AO are issued after issuing re-assessment notice: ITAT ...
I-T - Role of remitter banker is simply to follow extant procedure and to deduct Tax at source as prescribed under statute: ITAT...
I-T - If payroll of assessee is in India during assignment period but entire salary reported in Form No.16 is cross charged to Singapore entity, ...
I-T - If assessee is not having any PE in India and is covered by India US DTAA and MOA, nature of services rendered by assessee on account of wh...
TP - If warranty cost claim stands reimbursed by AE to assessee as per term of inter-company agreement, same would not tantamount to value additi...
I-T - If assessee doesn't have Dependent Agent PE / Installation PE in India, receipts on account of Drawing and Design can't be taxed as Income ...
TP - In transfer pricing matters, it is not sufficient for ITAT to determine ALP without referring to & applying relevant statutory framework & g...
TP - If no default is noticed by TPO regarding non-maintenance of information u/s 92D r/w Rule 10D, then AO can't impose penalty u/s 271AA for no...
https://taxindiainternational.com/case_lawDesc.php?qwer43fcxzt=MTQ3MTg= ...
DTAA - Delivery charges received by assessee where directly connected to its international air transportation business be considered part of its ...
INTL - Additions framed u/s 69 not tenable where link between remittance & assessee's business income is sufficiently explained: ITAT ...
I-T - Reopening can't be sustained, if AO had acted under dictation of his superiors and had issued notice to reopen assessment without himself h...
TP - Extended credit period or credit allowed over and above agreed period shall be considered as separate international transaction which would ...
TP - If there is no link between overdue outstanding receivable and extended credit period allowed to AEs, then both are separate international t...
I-T - If assessee was granted certificate at nil withholding tax for prior A.Ys and there is no issue to chargeability of assessee's income to ta...
 
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