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I-T - Applicability of Sec 151 in terms of determining specified authority to seek necessary approval will arise once period of limitation is det...
TP- Burden Lies on Assessee to Establish Currency of Loan for TP Adjustment: ITAT...
TP - Once TPO has passed order without making any adjustments, then AO could not have assumed jurisdiction to reopen assessment based on same fac...
I-T - Income Tax Act does not prohibit from first setting off STCG with STT against STCL with STT and then allow set off against STCG without STT...
I-T - Issue of excess DDT paid u/s 115-O, being independent of assessment of total income u/s 143(3), must be adjudicated in separate appeal u/s ...
I-T - Sale of ‘off-the-shelf' software under non-exclusive license does not attract TDS liability u/s 195: HC ...
TP - AO's failure to incorporate DRP's directions is erroneous, however it does not render the entire assessment order void: ITAT ...
TP - Goods supplied by low risk distributor without any value addition, without incurring any cost on account of finance charges, can be benchmar...
TP - ALP of management fees paid to AEs can't be taken at NIL, for failure of assessee to establish commercial benefit out of such transaction: I...
I-T - Cost-to-cost reimbursement of salary of seconded employees without any markup, without having element of profit, is not taxable in hands of...
TP - Forex gain/loss earned/incurred by assessee and other comparables needs to be considered as part of operating revenue/cost: ITAT ...
I-T - There is no prohibition with regard to hierarchy of set off of short term capital gain (STCG) arising out of securities transaction tax (ST...
I-T- Following amendment to Rule 128(9) of I-T Rules, effective from 01.04.2022, allowed FTC claims even if Form No. 67 was filed after the due d...
I-T - Salary payment made outside India is not covered by section 40(a)(i) and rather covered by section 40(a)(iii), and therefore, does not attr...
TP - If salary paid to global sales personnel is intrinsically linked to sale of software products & services to AE which was benchmarked using T...
I-T - If foreign automated Computer Information System pays 33% of booking fees to distributors, no income is attributable to tax in India: ITAT...
TP- Imputed interest on trade receivables not an international transaction - comparables excluded due to functional dissimilarity – prior year ...
I-T-Assessment u/s 147 r/w 144 quashed & case remanded where ex parte proceedings violate principles of natural justice: ITAT ...
TP - AO must carryout verification of internal TNMM applied by assessee for international transaction with AEs for export of spare parts and comp...
INTL - A transaction involving sale of property & resultant capital gains cannot be taxed again where such proceeds were already taxed in an earl...
 
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