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TP - AMP and R&T expenses do not constitute 'international transactions' u/s 92B in absence of agreement to provide services to AEs: ITAT (See Breaking News) DTAA - Receipts received by Hong Kong tax-resident assessee for providing managed, systems integration and hi-tech transactional services to Standard Chartered Bank through its Indian group company, not taxable in India as royalty or FTS: ITAT (See Breaking News)
 
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Breaking News
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Kolkata, Aug 21, 2026 By TII News Service
TP - AMP and R&T expenses do not constitute 'international transactions' u/s 92B in absence of agreement to provide services to AEs: ITAT ...
Mumbai, Aug 21, 2026 By TII News Service
DTAA - Receipts received by Hong Kong tax-resident assessee for providing managed, systems integration and hi-tech transactional services to Stan...
New Delhi, Aug 20, 2026 By TII News Service
TP - AMP expenses incurred by brand owner for its own business are revenue expenditures: ITAT ...
Mumbai, Aug 20, 2026 By TII News Service
TP - Statutory timelines prescribed u/s 144C(13) are mandatory, sacrosanct & fundamental to procedural discipline in tax administration - omissio...
New Delhi, Aug 19, 2026 By TII News Service
TP - Extending corporate guarantees falls within definition of international transactions u/s 92B as indirect long-term financing: ITAT ...
Mumbai, Aug 19, 2026 By TII News Service
I-T - Underwriting commissions do not constitute FTS because they represent fee for incurring financial risk rather than transmission of technica...
New Delhi, Aug 19, 2026 By TII News Service
I-T - Reimbursements did not attract TDS u/s 195: ITAT ...
Chandigarh, Aug 18, 2026 By TII News Service
TP - Revenue's attempt to treat draft order as final assessment order u/s 143(3) by alleging ‘human error' is unsustainable: HC ...
New Delhi, Aug 18, 2026 By TII News Service
I-T - Situs of manufacturing activity in India suggests that income component is located in India, even if receipts emanate from abroad: ITAT ...
Mumbai, Aug 18, 2026 By TII News Service
INTL - In absence of international transaction, statutory obligations to maintain documentation u/s 92D & Rule 10D does not arise, thereby render...
Mumbai, Aug 17, 2026 By TII News Service
I-T - Technical services are only taxable under ‘make available' if recipient absorbs skill to apply it independently: ITAT ...
Kolkata, Aug 17, 2026 By TII News Service
TP - ALP for international loans in foreign currency must be benchmarked against LIBOR applicable in borrower's country: ITAT ...
Bengaluru, Aug 14, 2026 By TII News Service
TP - Economic adjustments for non-creditable customs duties and working capital cycles are mandatory to ensure comparability: ITAT ...
Bengaluru, Aug 14, 2026 By TII News Service
TP - Parity must be maintained between operating cost and income base, specifically regarding ESOP reimbursements & foreign currency receivables:...
Ahmedabad, Aug 14, 2026 By TII News Service
TP - TNMM is preferred over CUP method if there are significant contractual and economic differences between AE & non-AE transactions that cannot...
Mumbai, Aug 13, 2026 By TII News Service
I-T - Section 44C is an exhaustive provision for head office expenses meeting a specific tripartite test - YES: ITAT ...
Pune, Aug 13, 2026 By TII News Service
I-T - Foreign taxes paid, such as Japanese Inhabitant or Enterprise taxes, that do not qualify for credit u/s 90/91, are allowable as business ex...
New Delhi, Aug 13, 2026 By TII News Service
TP - If entity is debt-free, it cannot be presumed that borrowed funds were utilized to provide credit facilities to AEs : ITAT ...
Mumbai, Aug 13, 2026 By TII News Service
DTAA - Receipts from transportation of cargo through feeder vessels obtained under slot hire arrangements are covered by Article 8 of the India-G...
Hyderabad, Aug 12, 2026 By TII News Service
TP - Profit margin agreed upon in Bilateral APA for specific AEs constitutes reliable benchmark for determining ALP of similar transactions with ...
 
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