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I-T - Consideration received for repair services is not FTS, where parts are sent abroad & returned after completion, without transfer of technical knowledge, skill or know-how enabling performance of such activities independently: ITAT (See Breaking News) I-T - Provisions of Rule 128 & requirement to file Form 67 were introduced prospectively from 01.04.2017; cannot be applied with retrospective effect: ITAT (See Breaking News) I-T - No additions can be sustained merely based on loose sheets, diary entries or oral statements of third party, unless corroborated with unaccounted transactions: ITAT (See Breaking News) GDP further shrinks in G20 economies in Q2 (See TII BRIEF) Live cricket broadcast - is It taxable as 'royalty'? (See TII SPECIAL) I-T - Issuing a notice u/s 148 to a non-existent, amalgamated entity is void ab initio and a nullity in the eyes of law: ITAT (See Breaking News) I-T - Detailed ratio payments for shared network services involving brand strategy do not constitute royalty if such services represent distribution of copyrighted articles without transfer of proprietary interest: ITAT (See Breaking News) TP - If TPO rejected entity on ground of persistent losses but assessee furnished evidence to demonstrate that company has made profit in subsequent year, such entity is to be included in list of comparable: ITAT (See Breaking News) TP - Commercial expediency & reasonableness of remuneration be judged from perspective of a businessman; AO cannot apply subjective standard or make presumptions: ITAT (See Breaking News) TP - Omission by AO to make formal reference to TPO is a procedural irregularity & not a incurable illegality; does not warrant outright quashing of assessment order: ITAT (See Breaking News) I-T - Broadcasting is neither ‘scientific work' nor does any copyright subsist in such rights, and fee received towards live broadcasting rights cannot be classified as royalty: ITAT (See Breaking News)
 
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I-T - Consideration received for repair services is not FTS, where parts are sent abroad & returned after completion, without transfer of technic...
I-T - Provisions of Rule 128 & requirement to file Form 67 were introduced prospectively from 01.04.2017; cannot be applied with retrospective ef...
I-T - No additions can be sustained merely based on loose sheets, diary entries or oral statements of third party, unless corroborated with unacc...
I-T - Issuing a notice u/s 148 to a non-existent, amalgamated entity is void ab initio and a nullity in the eyes of law: ITAT...
I-T - Detailed ratio payments for shared network services involving brand strategy do not constitute royalty if such services represent distribut...
TP - Omission by AO to make formal reference to TPO is a procedural irregularity & not a incurable illegality; does not warrant outright quashing...
TP - Commercial expediency & reasonableness of remuneration be judged from perspective of a businessman; AO cannot apply subjective standard or m...
TP - If TPO rejected entity on ground of persistent losses but assessee furnished evidence to demonstrate that company has made profit in subsequ...
I-T - Broadcasting is neither ‘scientific work' nor does any copyright subsist in such rights, and fee received towards live broadcasting right...
TP - TPO cannot determine ALP at Nil by questioning necessity or benefit of services: ITAT ...
TP - Foreign exchange gains & losses arising from realization of normal export sale proceeds in course of business with associated enterprises, a...
I-T - Rejection of assessee's claim cannot per se justify levy of penalty for under-reporting or misreporting of income: ITAT ...
TP - Assessment order is complete only on being digitally signed - order is barred by limitation where date borne on order or date on which AO co...
TP - Characterization of entity for transfer pricing purposes must be based on detailed FAR analysis: ITAT ...
DTAA - Corporate charges paid for intra-group managerial, administrative, marketing & business support services & not making available any techni...
I-T - Reimbursements of salary for seconded employees made on cost-to-cost basis without income element are not taxable in hands of foreign recip...
TP - In absence of agreement, arrangement, or understanding between assessee & its AE to share or incur AMP expenses for sole benefit of AE, dome...
TP - No notional interest can be imputed on trade receivables if assessee is debt-free entity: ITAT ...
TP - While an APA is not strictly binding on AYs outside its formal coverage, pricing methodology & agreed margins have strong persuasive value, ...
I-T - Regulatory evidence from bank and RBI confirming identity theft and fraudulent account opening overrides any presumptions arising solely fr...
 
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