Tuesday , August 25, 2026 |   19:16:07 IST
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INTL - Although outstanding receivables from an AE constitute a separate international transaction amenable to benchmarking, determination of ALP has to depend upon the facts and circumstances of each case: ITAT (See Breaking News) TP - An APA concluded by CBDT, though not directly applicable to earlier AY, has significant persuasive value where nature of international transactions & FAR profile remain comparable: ITAT (See Breaking News) INTL - Penalties u/s 271AA & 271G not valid where AO failed to point out any specific missing documents & where TPO already accepted transactions at arm's length after verification: ITAT (See Breaking News) TP - Huge turnover or profit cannot serve as sole basis for exclusion of comparable if company is otherwise functionally comparable under Rule 10B(2): ITAT (See Breaking News) TP - Once tested party's margins are found to be at arm's length under TNMM, and adequate working capital adjustment is made, no separate adjustment on account of notional interest on delayed receivables from AEs is warranted: ITAT (See Breaking News) TP - For benchmarking interest on External Commercial Borrowing obtained from Associated Enterprise, CUP method is most appropriate method, as price of lending transaction can be directly compared with comparable uncontrolled loans: ITAT (See Breaking News) TP - AMP and R&T expenses do not constitute 'international transactions' u/s 92B in absence of agreement to provide services to AEs: ITAT (See Breaking News) DTAA - Receipts received by Hong Kong tax-resident assessee for providing managed, systems integration and hi-tech transactional services to Standard Chartered Bank through its Indian group company, not taxable in India as royalty or FTS: ITAT (See Breaking News)
 
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Breaking News
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Chennai, Aug 25, 2026 By TII News Service
INTL - Although outstanding receivables from an AE constitute a separate international transaction amenable to benchmarking, determination of ALP...
New Delhi, Aug 25, 2026 By TII News Service
TP - An APA concluded by CBDT, though not directly applicable to earlier AY, has significant persuasive value where nature of international trans...
Pune, Aug 25, 2026 By TII News Service
INTL - Penalties u/s 271AA & 271G not valid where AO failed to point out any specific missing documents & where TPO already accepted transactions...
New Delhi, Aug 24, 2026 By TII News Service
TP - Huge turnover or profit cannot serve as sole basis for exclusion of comparable if company is otherwise functionally comparable under Rule 10...
Ahmedabad, Aug 24, 2026 By TII News Service
TP - Once tested party's margins are found to be at arm's length under TNMM, and adequate working capital adjustment is made, no separate adjustm...
Ahmedabad, Aug 24, 2026 By TII News Service
TP - For benchmarking interest on External Commercial Borrowing obtained from Associated Enterprise, CUP method is most appropriate method, as pr...
Kolkata, Aug 21, 2026 By TII News Service
TP - AMP and R&T expenses do not constitute 'international transactions' u/s 92B in absence of agreement to provide services to AEs: ITAT ...
Mumbai, Aug 21, 2026 By TII News Service
DTAA - Receipts received by Hong Kong tax-resident assessee for providing managed, systems integration and hi-tech transactional services to Stan...
New Delhi, Aug 20, 2026 By TII News Service
TP - AMP expenses incurred by brand owner for its own business are revenue expenditures: ITAT ...
Mumbai, Aug 20, 2026 By TII News Service
TP - Statutory timelines prescribed u/s 144C(13) are mandatory, sacrosanct & fundamental to procedural discipline in tax administration - omissio...
New Delhi, Aug 19, 2026 By TII News Service
TP - Extending corporate guarantees falls within definition of international transactions u/s 92B as indirect long-term financing: ITAT ...
Mumbai, Aug 19, 2026 By TII News Service
I-T - Underwriting commissions do not constitute FTS because they represent fee for incurring financial risk rather than transmission of technica...
New Delhi, Aug 19, 2026 By TII News Service
I-T - Reimbursements did not attract TDS u/s 195: ITAT ...
Chandigarh, Aug 18, 2026 By TII News Service
TP - Revenue's attempt to treat draft order as final assessment order u/s 143(3) by alleging ‘human error' is unsustainable: HC ...
New Delhi, Aug 18, 2026 By TII News Service
I-T - Situs of manufacturing activity in India suggests that income component is located in India, even if receipts emanate from abroad: ITAT ...
Mumbai, Aug 18, 2026 By TII News Service
INTL - In absence of international transaction, statutory obligations to maintain documentation u/s 92D & Rule 10D does not arise, thereby render...
Mumbai, Aug 17, 2026 By TII News Service
I-T - Technical services are only taxable under ‘make available' if recipient absorbs skill to apply it independently: ITAT ...
Kolkata, Aug 17, 2026 By TII News Service
TP - ALP for international loans in foreign currency must be benchmarked against LIBOR applicable in borrower's country: ITAT ...
Bengaluru, Aug 14, 2026 By TII News Service
TP - Economic adjustments for non-creditable customs duties and working capital cycles are mandatory to ensure comparability: ITAT ...
Bengaluru, Aug 14, 2026 By TII News Service
TP - Parity must be maintained between operating cost and income base, specifically regarding ESOP reimbursements & foreign currency receivables:...
 
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