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TP - TPO's action of determining ALP at NIL without applying any prescribed method u/s 92C & without properly rejecting assessee's benchmarking analysis, is unsustainable: ITAT (See Breaking News) I-T - Entitlement to tax withholding certificate at ‘NIL' rate depends on agreement between parties: HC (See Breaking News) TP - Overdue receivables from AE are considered a separate international transaction of 'capital financing' under Explanation 1(c) to Section 92B and must be benchmarked separately: ITAT (See Breaking News) INTL -Limitation prescribed u/s 153 continues to apply even where assessment is framed through draft order procedure u/s 144C: ITAT (See Breaking News) INTL - Where final assessment order had been passed beyond outer time limit prescribed u/s 153 r/w Section 144C, the order is thus barred by limitation & therefore liable to be quashed: ITAT (See Breaking News) I-T - Nature of adjudication by AAR is akin to 'reference', and application u/s 245Q is covered under ambit of any proceedings as mentioned in Sec 150: HC (See Breaking News) I-T - Provisions of Section 144C are part of assessment procedure and do not override absolute limitation period set by Section 153 for completion of assessment: ITAT (See Breaking News) I-T - Period of limitation for passing final assessment order u/s 144C(13) must be determined by combined reading of Section 144C and Section 153: ITAT (See Breaking News) I-T - Payments made by Indian subsidiary to its foreign parent company as reimbursement for arranging centralized facilities that support subsidiary's business operations are classifiable as 'managerial services', taxable as FTS: ITAT (See Breaking News) I-T - Final assessment order passed beyond statutory time limit prescribed under Section 153 is barred by limitation and is liable to be quashed: ITAT (See Breaking News)
 
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TP - TPO's action of determining ALP at NIL without applying any prescribed method u/s 92C & without properly rejecting assessee's benchmarking a...
I-T - Entitlement to tax withholding certificate at ‘NIL' rate depends on agreement between parties: HC...
TP - Overdue receivables from AE are considered a separate international transaction of 'capital financing' under Explanation 1(c) to Section 92B...
INTL -Limitation prescribed u/s 153 continues to apply even where assessment is framed through draft order procedure u/s 144C: ITAT...
INTL - Where final assessment order had been passed beyond outer time limit prescribed u/s 153 r/w Section 144C, the order is thus barred by limi...
I-T - Nature of adjudication by AAR is akin to 'reference', and application u/s 245Q is covered under ambit of any proceedings as mentioned in Se...
I-T - Provisions of Section 144C are part of assessment procedure and do not override absolute limitation period set by Section 153 for completio...
I-T - Period of limitation for passing final assessment order u/s 144C(13) must be determined by combined reading of Section 144C and Section 153...
I-T - Payments made by Indian subsidiary to its foreign parent company as reimbursement for arranging centralized facilities that support subsidi...
I-T - Final assessment order passed beyond statutory time limit prescribed under Section 153 is barred by limitation and is liable to be quashed:...
I-T-Interest income earned on deposits maintained due to business or statutory requirements where inextricably linked to business activity, is el...
I-T - Section 163(1)(c), a person can be treated as agent of non-resident only if non-resident receives income directly or indirectly from or thr...
DTAA - Virtual Service Permanent Establishment (VSPE) cannot be read into provisions of DTAA, as Article 5 of India-UK Treaty makes no provision ...
I-T - Assessment order passed after expiry of time limit stipulated in section 153 is barred by limitation and is invalid in law, even if it adhe...
I-T - If assessee possesses sufficient own interest-free funds that exceed interest-free advances, it is presumed that advances were made from th...
TP - Section 92BA(i), governing specified domestic transactions, stands omitted without any saving clause & therefore, is to be treated as non-ex...
TP - Transfer pricing adjustment on international transaction involving payment of interest to AE is not warranted if assessee has already suo mo...
TPO - In case involving reference to Transfer Pricing Officer, time limit for completing assessment is extended by 12 months as per Section 153(4...
I-T - Appeal against a final assessment order lies before the Commissioner Appeals, and not directly before the Tribunal: ITAT ...
I-T - Pure error of law based on plausible understanding of law, if income was fully disclosed in accounts and neither concealed nor inaccurately...
 
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