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A single tax with multiple governing Acts (See 'taxindiaonline') DTAA - Only consideration for development & transfer of technical plan/design gets covered under 'FTS' and not 'consideration for their management/supervision' as per Article 12(4)(b) of India USA DTAA: ITAT (See 'Breaking News') TP - If final assessment order passed by NFAC to extent of TP adjustment is not in accordance with directions of DRP, then TP adjustment to such extent deserves to be quashed: ITAT (See 'Breaking News') I-T - Deductions contemplated u/s 10A was qua profits of eligible undertaking of taxpayer on stand-alone basis and without reference to other eligible or non-eligible units or undertakings of assessee: ITAT (See 'Breaking News') I-T - Credit for taxes paid by assessee in Japan, Swiss Federation and Malaysia is eligible for credit subject to limitation of such relief not exceeding that part of tax which is attributable to income to be taxed in Japan, Swiss and Malaysia: ITAT (See 'Breaking News') A peep into President Biden's Fiscal-verse! (See 'TII EDIT') Govt constitutes collegium for deciding deferment of appeals before the Appellate Tribunal or the jurisdictional High Court by the Assessing Officer (See 'Bulletin Board ') Trade Based Money-Laundering: A Critical Analysis (See 'taxindiaonline') 'Crooked' Recession looms large! Let curve of your smile set it 'straight'! (See 'taxindiaonline') TP - Computation of Arm's Length Price based on incorrect assumption of services rendered, would cause prejudice to computation of ALP - case remanded: ITAT (See 'Breaking News')
 
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I-T - Credit for taxes paid by assessee in Japan, Swiss Federation and Malaysia is eligible for credit subject to limitation of such relief not e...
DTAA - Only consideration for development & transfer of technical plan/design gets covered under 'FTS' and not 'consideration for their managemen...
TP - If final assessment order passed by NFAC to extent of TP adjustment is not in accordance with directions of DRP, then TP adjustment to such ...
I-T - Deductions contemplated u/s 10A was qua profits of eligible undertaking of taxpayer on stand-alone basis and without reference to other eli...
DTAA - transfer of copyright including right to make copy of software for international business, any payment made therefor, qualifies as royalty...
TP - any amount cannot be subject to disallowance, where it has not been claimed or adjusted while computing taxable income: ITAT...
TP - Computation of Arm's Length Price based on incorrect assumption of services rendered, would cause prejudice to computation of ALP - case rem...
TP - company which manufactures textiles cannot be adopted as comparable in respect of a company that manufactures textile machines, for benchmar...
TP - Once international transaction between assessee and AE is with regard to receivables, then it has to be looked upon by applying commercial p...
TP - Tribunal is not required to admit additional grounds raised by assessee where they do not emanate from orders of lower authorities: ITAT ...
I-T - Once credits are given to airline as consideration for selection of IAE engines to be fitted in aircrafts manufactured by Airbus, such cred...
TP - RPM is most appropriate method of benchmarking for pure trading company involved in distribution activity without adding any value to purcha...
TP - Assessee cannot change benchmarking and comparability analysis at his own whims and fancies: ITAT...
TP - benefit whether or not arising, is not essential criteria for claiming deduction in respect of business expenditure: ITAT ...
TP - Separate adjustment for interest on delayed receivables is to be computed if assessee is not charging interest on delayed receivables from u...
TP - Mere accrual of incidental benefit is no reason to render AMP expenses incurred by Indian subsidiary on behalf of its foreign parent company...
TP - corporate guarantee extended to AEs is covered under limb of international transaction and having bearing on profit & loss account: ITAT...
DTAA - Taxation of foreign companies at higher rate vis-à-vis domestic companies cannot be considered as discriminatory: ITAT...
I-T - Tax authorities cannot simply calculate profit as per Rule 115 and also add if there is any difference in opening and closing stock valuati...
TP - If payment of interest by Assessee on behalf of its AE is not claimed as expenditure, same is revenue neutral and Chapter X of Income tax Ac...
 
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