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TP - If no adjustment can be made in respect of transaction with unrelated parties u/s 92, then DRP should call for required details, rather than adjudicating on non-AE transactions: ITAT (See 'Breaking News') TP - New proviso to Sec 40A is saving clause by virtue of which, any specified transaction on or before April 01, has to be tested as per provisions of Sec 92C: ITAT (See 'Breaking News') Global Economy in COVID-induced coma - India needs to clear 'political fog' & take bold decisions (See 'taxindiaonline.com') DTAA - Payment made by resident distributors to foreign suppliers for purchase of shrinkwrapped software, does not amount to royalty: ITAT (See 'Breaking News') I-T - Contradictions due to complex web of arrangements involving large number of entities in several jurisdictions in fragmented manner, cannot be put against bonafides of tax demands at stage of stay: ITAT (See 'Breaking News') TP - Power of reassessment of AO for collecting evidences or informations from TPO cannot be crippled down by wrongly interpreting Section 92CA(2B) or (2C): HC (See 'Breaking News') Tax collections in Asia hit by pre-COVID recession: OECD (See 'TII BREIF') Pure software developer is not comparable to software product company having huge intangible asset & brand value: ITAT (See 'Breaking News') DTAA - Project office of foreign company which merely acts as 'communication channel' without any authority to conclude contract, cannot be termed as 'PE': ITAT (See 'Breaking News') Simply because appeal by Revenue is revived at instance of assessee because of its proceedings in HC, that would by no stretch of imagination make such appeal before ITAT, an appeal by assessee u/s 253 of I-T Act: HC (See 'Breaking News') HANDLING OF SEIZED GOODS UNDER THE CUSTOMS ACT, 1962 (See TOG 'THE INSIGHT') TP - Captive service provider cannot be selected as comparable in absence of segmental information and huge functional difference: ITAT (See 'Breaking News') TP - Entity which has committed fraud, as per findings of SEBI regulations, cannot be considered as good comparable for captive service provider: ITAT (See 'Breaking News')
 
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TP - New proviso to Sec 40A is saving clause by virtue of which, any specified transaction on or before April 01, has to be tested as per provisi...
TP - If no adjustment can be made in respect of transaction with unrelated parties u/s 92, then DRP should call for required details, rather than...
DTAA - Payment made by resident distributors to foreign suppliers for purchase of shrinkwrapped software, does not amount to royalty: ITAT...
I-T - Contradictions due to complex web of arrangements involving large number of entities in several jurisdictions in fragmented manner, cannot ...
TP - Power of reassessment of AO for collecting evidences or informations from TPO cannot be crippled down by wrongly interpreting Section 92CA(2...
DTAA - Project office of foreign company which merely acts as 'communication channel' without any authority to conclude contract, cannot be terme...
Pure software developer is not comparable to software product company having huge intangible asset & brand value: ITAT...
Simply because appeal by Revenue is revived at instance of assessee because of its proceedings in HC, that would by no stretch of imagination mak...
TP - Entity which has committed fraud, as per findings of SEBI regulations, cannot be considered as good comparable for captive service provider:...
TP - Captive service provider cannot be selected as comparable in absence of segmental information and huge functional difference: ITAT...
I-T - No withholding tax liability can be fastened upon taxpayer, without verifying if subject payments are actually 'reimbursements' or not: ITA...
TP - Procedural delay on part of assessee cannot per se result in levy of penalty u/s 271B: ITAT ...
TP - If close association between seller and buyer and their 'arranged' pricing were adequately substantiated by TPO, then such case calls for AL...
Amounts paid by resident Indian distributors to foreign software suppliers, as consideration for use of offshelf software, is not payment of roya...
TP - Stay on recovery of duty demand merits being allowed where the assessee is willing to pay 20% of duty demand raised & where the case is prim...
TP - Huge difference in turnover filter is sufficient basis for excluding such comparables for purposes of benchmarking: ITAT...
TP - Every ALP adjustment could only be made going by uncontrolled market price of transactions in that very segment: ITAT...
Income earned by taxpayer through onsite development of software by its AE would be eligible for deduction u/s 10B: HC...
I-T - Tax effect less than threshold limit stipulated by way of CBDT Circular, calls for dismissal of appeal: HC...
I-T - There is no obligation in law to deduct TDS on payments made for reimbursement of costs incurred by non-resident enterprise: HC...
 
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