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TP - Working capital adjustment, foreign exchange fluctuation adjustment, and capacity utilization adjustment, shall be applied to international ...
TP - Royalty payment made by assessee to its AE cannot be subjected to TP adjustment when royalty is not embedded in import price: ITAT ...
TP - Penalty u/s 271BA cannot be sustained where foundational provision, namely section 92BA(i), is already omitted when penalty proceedings were...
I-T - Services rendered by individual based on his personal expertise, market knowledge & industry experience cannot automatically be characteri...
DTAA - Borrowed services fees does not satisfy 'make available' requirement under Article 13(4) of India-UK DTAA: ITAT ...
I-T - Profits attributable to non-UK resident partners of UK partnership firm providing legal services in India cannot be taxed as Fees for Techn...
TP - Fully & compulsorily convertible debentures are hybrid instruments & continue to operate as debt until actually converted into equity shares...
TP - Final assessment order is invalidated where passed without incorporating the adjustments mandated by the DRP: ITAT ...
I-T - Offshore supply profits are not taxable in India and reimbursement of expatriate salary is not FTS: ITAT ...
I-T - Lease rentals received by Irish aircraft lessors from Indian airlines are not taxable in India: ITAT ...
I-T - Payments towards renewal of software licences from resident suppliers does not attract Section 194J: HC ...
I-T - Interest received from and paid to Head Office and overseas branches on NOSTRO accounts, being self-to-self transaction under principle of ...
INTL - Burden to prove genuineness of cash credits & disputed receipts squarely rests on assessee - presentation of formal documentation is per s...
INTL - Re-assessment invalidated where sanction for order u/s 148A(d) & notice u/s 148 is granted by Pr. CIT despite expiry of 3-year period, whe...
DTAA - Deploying specialized software, technical resources, or copyrighted items as medium to deliver services does not amount to granting right ...
I-T - Assessee is entitled to concessional rate u/s 115BAA despite delayed filing of Form 10-IC, when option had already been exercised in return...
INTL - Once Revenue accepts that no income is taxable in India for relevant AY, the corresponding TDS deducted at source cannot be withheld & ass...
INTL - Digital transmission & uploading of orders on ITBA portal is valid receipt by AO, effectively starting limitation clock from that date rat...
DTAA - Payment for managerial, technical or consultancy services constitutes Fees for Technical Services only where such services are provided by...
I-T - Final assessment order passed u/s 143(3), 144C(13) and 144B can be quashed as time-barred if it is passed beyond outer limitation prescribe...
 
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