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TP - Cognizance taken by AO u/s 92CA is invalid, if it has been omitted from statute itself: ITAT...
TP - Internal TNMM is more superior than external TNMM, more so when audited segmental are available: ITAT...
TP - Interest payable on NCDs whivh are denominated in Indian currency is to be benchmarked by applying PLR as against LIBOR: ITAT...
I-T - GST would not form part of gross receipts for purposes of computing income u/s 44BB: ITAT...
I-T - If contract was only for provision of services and not for supply of technical designs, and assessee has not made available technical knowl...
I-T -Disallowance u/s 40(a)(ia) for non-deduction of TDS on bank guarantee commission is not tenable where no principal-agent relationship exists...
I-T - Sec 206AA Income Tax Act requiring 20% TDS deduction in absence of PAN, doesn't override beneficial rates of tax under treaty, if receipien...
I-T - Delay in filing Form no.67 shall be condoned so as to enable assessee to get credit of tax paid at Bangladesh on salary earned by assessee ...
I-T - Once assessee proves its residential status as non-resident covered under DTAA, based on investigations carried out by SEBI & RBI, it is el...
I-T - Subscription payments received for providing cloud services are not taxable as royalty: HC...
TP - Company having no relevant segmental information for benchmarking analysis, despite having revenue earnings from multiple streams, merits ex...
TP - Test of presence of commercial benefit is essentially in domain of Sec 37 and jurisdiction of TPO is only limited to find out if prices paid...
I-T - Once income from supply of plant & equipment is held to be not taxable in India, since sale transaction was completed outside India, same l...
I-T - Gain on MTM which has been held to be treated as income of assessee in order passed u/s 154 can be reversed in case MTM loss is held to be ...
TP - Reimbursement received at cost does not require any mark-up: ITAT...
TP - AMP expenditure is not unilateral and out of some discernible arrangement which is reflected in concert action between assessee and AE: ITAT...
TP - Adjustment on AMP and disallowance of reimbursements deleted; no international transaction established: ITAT...
I-T - Department must issue necessary instructions to all Assessment Units/Penalty Units as per Sec 144B(3), to ensure that AO who provides for V...
I-T - Absence of interest does not derogate from assessee substantive right to receive refund, which he would have otherwise been entitled to, ha...
TP - ALC at which power is procured by non-eligible units from SEB is most appropriate ALP to bench mark specified domestic transactions: ITAT...
 
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