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TP - Value of international transaction pertaining to low end IS&T services reconciled with segment revenue, should be considered to compute margin: ITAT (See Breaking News) I-T - Penalty u/s 271(1)(c) cannot be sustained as there is no conclusive finding of concealment or furnishing of inaccurate particulars: ITAT (See Breaking News) How to woo FDI into India? (See TII SPECIAL) TP - Company merits being dropped as comparable where regulatory findings reveal financial irregularities & diversion of funds, rendering its financial results & operating margins unreliable: ITAT (See Breaking News) TP - Once the DRP directions were uploaded on ITBA portal in September 2024, then AO is required to pass final assessment order within one month from end of that month: ITAT (See Breaking News) I-T - If final assessment order is passed beyond limitation period computed under Section 144C r/w/s 153, such order is without jurisdiction: ITAT (See Breaking News) DTAA - Reimbursement does not contain any income element so as to be taxed as Fees for Technical Services either under I-T Act or under India–Japan tax treaty: ITAT (See Breaking News) DTAA - DDT u/s 115-O is tax levied on distributed profits of domestic company & not on income of shareholder; ergo does not fall within scope of DTAA benefits - YES: ITAT (See Breaking News) I-T- Final assessment order passed in violation of binding DRP directions is void ab initio: ITAT (See Breaking News) DTAA - Excess DDT paid u/s 115-O can be refunded u/s 237 even if not claimed in return due to ITR utility limitation; DTAA rate of 10% applies to DDT: ITAT (See Breaking News) I-T - Consultancy receipts cannot be taxed in India as business income in hands of non-resident in absence of evidence establishing business connection, PE, or fixed base in India: ITAT (See Breaking News) DTAA - Referral fee is purely a commercial income arising from introduction of clients & does not involve any managerial, technical or consultancy services; cannot be treated as FTS: ITAT (See Breaking News) TP - Internal CUP based on tariff charged charged by DGVCL to consumers is reliable benchmark: ITAT (See Breaking News) The 2026 Income Tax Ordinance and non-residents (See TII Edit) DTAA - Re-assessment is invalidated where commenced on incorrect assumption of facts: ITAT (See Breaking News) TP - Variations in functional profile, turnover filter and RPT filter, calls for exclusion of comparable for benchmarking purposes: ITAT (See Breaking News)
 
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TP - Value of international transaction pertaining to low end IS&T services reconciled with segment revenue, should be considered to compute marg...
I-T -Penalty u/s 271(1)(c) cannot be sustained as there is no conclusiv e finding of concealment or furnishing of inaccurate particulars: ITAT ...
TP - Company merits being dropped as comparable where regulatory findings reveal financial irregularities & diversion of funds, rendering its fin...
TP - Once the DRP directions were uploaded on ITBA portal in September 2024, then AO is required to pass final assessment order within one month ...
I-T - If final assessment order is passed beyond limitation period computed under Section 144C r/w/s 153, such order is without jurisdiction: ITA...
DTAA - Reimbursement does not contain any income element so as to be taxed as Fees for Technical Services either under I-T Act or under India–J...
DTAA - DDT u/s 115-O is tax levied on distributed profits of domestic company & not on income of shareholder; ergo does not fall within scope of ...
I-T- Final assessment order passed in violation of binding DRP directions is void ab initio: ITAT ...
DTAA - Excess DDT paid u/s 115-O can be refunded u/s 237 even if not claimed in return due to ITR utility limitation; DTAA rate of 10% applies to...
I-T - Consultancy receipts cannot be taxed in India as business income in hands of non-resident in absence of evidence establishing business conn...
DTAA - Referral fee is purely a commercial income arising from introduction of clients & does not involve any managerial, technical or consultanc...
TP - Internal CUP based on tariff charged charged by DGVCL to consumers is reliable benchmark: ITAT...
DTAA - Re-assessment is invalidated where commenced on incorrect assumption of facts: ITAT ...
TP - Variations in functional profile, turnover filter and RPT filter, calls for exclusion of comparable for benchmarking purposes: ITAT ...
I-T - Outer time limit prescribed u/s 153 applies to entire assessment process, including proceedings before DRP: ITAT ...
I-T - Final assessment orders barred by limitation as per Section 153 r.w. Section 144C, are void ab initio and liable to be quashed: ITAT...
I-T - Funds sourced from foreign earnings & credited to NRE accounts cannot be treated as unexplained income where Department does not produce ev...
I-T - Subscription-based access to journals, e-magazines or databases is not FTS, unless content is specifically rendered for user's individual r...
TP - Revenue-neutral related party payments do not justify transfer pricing adjustment where there is no tax arbitrage: ITAT ...
I-T - Payments made to foreign telecom operators for data transmission services outside India are not royalty under DTAA so as to trigger withhol...
 
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