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NEWS FLASH   I-T- Compulsorily Convertible Debentures & Optionally Convertible Debentures, until conversion, retain essential characteristics of debt instruments akin to NCDs; ergo, qualify as debentures or bonds for tax purposes: ITAT (See Breaking News) TP - Separate adjustment for receivables results in duplication, if economic effect of extended credit period is already subsumed in working capital adjustment: ITAT (See Breaking News) I-T -Payments received by assessee will be business profits rather than royalty, where assessee merely organizes publicly available scientific information in a database & provides access to it, without transferring any copyright or proprietary rights to customers: ITAT (See Breaking News) TP - TPO's approach in insisting upon daily/monthly working capital cycle data of third-party comparable is, unjustified if such data is admittedly not available in public domain: ITAT (See Breaking News) TP- TNMM operates at net margin level & tolerates transactional differences; hence pricing mechanism or revenue scale alone cannot justify rejection of internal TNMM: ITAT (See Breaking News) INTL - As is trite law, filing of Form 67 is directory and not mandatory; delay in filing Form 67 should not lead to disallowance of Foreign Tax Credit: ITAT (See Breaking News) TP - Reference which was made to TPO after date when clause (i) of section 92BA was omitted by Finance Act, 2017, is not sustainable: ITAT (See Breaking News) I-T - Reimbursement of salary paid to AEs which are merely in nature of reimbursements of seconded employee and does not include any element of income, does not attract TDS: ITAT (See Breaking News) I-T - Final assessment order passed by AO merits to be quashed if it is not in conformity with DRP directions: ITAT (See Breaking News) I-T - If allocation/attribution of income to PE is at arm's length, then no further ad-hoc attribution is required: ITAT (See Breaking News) TP - While principle of res judicata does not apply to tax proceedings, the principle of consistency must be observed, especially where there is no change in facts or legal position: ITAT (See Breaking News) TP - Provision for bad & doubtful debts is only accounting treatment and have no direct nexus to operating income: ITAT (See Breaking News) TP - Working capital adjustment can't be denied merely due to absence of detailed working capital cycle data and adjustment should be granted based on average of opening & closing balances: ITAT (See Breaking News) DTAA - Prior taxability of similar income in earlier years does not bar assessee's lawful claim for relief in current year, more so when there is no change in facts: ITAT (See Breaking News) Netherlands to grow at 1.3% rate in 2025: OECD (See Brief) TP - Corporate guarantee given by assessee on behalf of AE in absence of any expenditure being incurred by assessee, would not constitute international transaction within meaning of Sec 92B: ITAT (See Breaking News) TP - Gross profitability margin may vary significantly over time, and hence, reliance on data of earlier years would not constitute reliable benchmark: ITAT (See Breaking News) DTAA - Management support services do not make available any technical knowledge or skill to recipient; ergo, consideration therefor is not taxable as FTS under India-Singapore DTAA: ITAT (See Breaking News) I-T - Amortization of capital subsidy in itself is not allowable as direct deduction u/s 80-IC, rather impact of capital subsidy is reflected in reduced "actual cost" of asset, leading to claim of lower depreciation: ITAT (See Breaking News) I-T - If repair & maintenance of aircraft equipment provided by foreign assessee to Indian airline operators, did not involve transfer of technology, then receipts from said services are not taxable as FIS: HC (See Breaking News) TP - If number of transactions are closely linked, then same should be treated as composite transaction and can be aggregated and construed as single transaction for purpose of determining ALP: ITAT (See Breaking News)   SIGN IN   Username Password Forgot Password   Home >> Breaking News   Breaking News  First    Previous Record 1 to 20 of 10908 Next     Last    New Delhi, Jul 18, 2025 By TII News Service I-T- Compulsorily Convertible Debentures & Optionally Convertible Debentures, until conversion, retain essential characteristics of debt instrume... Ahmedabad, Jul 18, 2025 By TII News Service TP - Separate adjustment for receivables results in duplication, if economic effect of extended credit period is already subsumed in working capi... Mumbai, Jul 17, 2025 By TII News Service I-T -Payments received by assessee will be business profits rather than royalty, where assessee merely organizes publicly available scientific in... Hyderabad, Jul 17, 2025 By TII News Service TP - TPO's approach in insisting upon daily/monthly working capital cycle data of third-party comparable is, unjustified if such data is admitted... Mumbai, Jul 16, 2025 By TII News Service TP- TNMM operates at net margin level & tolerates transactional differences; hence pricing mechanism or revenue scale alone cannot justify reject... Hyderabad, Jul 16, 2025 By TII News Service INTL - As is trite law, filing of Form 67 is directory and not mandatory; delay in filing Form 67 should not lead to disallowance of Foreign Tax ... New Delhi, Jul 15, 2025 By TII News Service TP - Reference which was made to TPO after date when clause (i) of section 92BA was omitted by Finance Act, 2017, is not sustainable: ITAT... Chennai, Jul 15, 2025 By TII News Service I-T - Reimbursement of salary paid to AEs which are merely in nature of reimbursements of seconded employee and does not include any element of i... Mumbai, Jul 14, 2025 By TII News Service I-T - Final assessment order passed by AO merits to be quashed if it is not in conformity with DRP directions: ITAT... Mumbai, Jul 14, 2025 By TII News Service I-T - If allocation/attribution of income to PE is at arm's length, then no further ad-hoc attribution is required: ITAT... New Delhi, Jul 11, 2025 By TII News Service TP - While principle of res judicata does not apply to tax proceedings, the principle of consistency must be observed, especially where there is ... Hyderabad, Jul 11, 2025 By TII News Service TP - Provision for bad & doubtful debts is only accounting treatment and have no direct nexus to operating income: ITAT... Hyderabad, Jul 10, 2025 By TII News Service TP - Working capital adjustment can't be denied merely due to absence of detailed working capital cycle data and adjustment should be granted bas... Mumbai, Jul 10, 2025 By TII News Service DTAA - Prior taxability of similar income in earlier years does not bar assessee's lawful claim for relief in current year, more so when there is... Vizag, Jul 09, 2025 By TII News Service TP - Corporate guarantee given by assessee on behalf of AE in absence of any expenditure being incurred by assessee, would not constitute interna... Mumbai, Jul 09, 2025 By TII News Service TP - Gross profitability margin may vary significantly over time, and hence, reliance on data of earlier years would not constitute reliable benc... Mumbai, Jul 08, 2025 By TII News Service DTAA - Management support services do not make available any technical knowledge or skill to recipient; ergo, consideration therefor is not taxab... Hyderabad, Jul 08, 2025 By TII News Service I-T - Amortization of capital subsidy in itself is not allowable as direct deduction u/s 80-IC, rather impact of capital subsidy is reflected in ... New Delhi, Jul 07, 2025 By TII News Service I-T - If repair & maintenance of aircraft equipment provided by foreign assessee to Indian airline operators, did not involve transfer of technol... New Delhi, Jul 07, 2025 By TII News Service TP - If number of transactions are closely linked, then same should be treated as composite transaction and can be aggregated and construed as si...   TII SEARCH   Case Law Advanced Search Case Laws Quick Search Circular/Notification/Instruction DTAA News Social Secuirity Agreement

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