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NEWS FLASH
DTAA - Profits of non-resident assessee would be taxable only in its resident state, and is eligible for tax withholding certificate in identical cases, unless assessee carried on business in India through PE: HC (See Breaking News)
TP - Since CCDs issued by assessee are in nature of rupee denominated loan, FCCD/CCD can't be construed on par with foreign currency loan for purpose of benchmarking: ITAT SB (See Breaking News)
TP - Aaccceptance of terms of buyer on commercial considerations, becomes influence for purpose of Sec 92A(2)(i), if seller has no choice but to accept it, because of buyer's dominant influence: ITAT (See Breaking News)
TP - Outstanding dues beyond agreed credit period in case of assessee are separate international transaction, requires to be benchmarked separately and cannot be clubbed together: ITAT (See Breaking News)
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New Delhi, Feb 21, 2025 By TII News Service
DTAA - Profits of non-resident assessee would be taxable only in its resident state, and is eligible for tax withholding certificate in identical...
Hyderabad, Feb 21, 2025 By TII News Service
TP - Since CCDs issued by assessee are in nature of rupee denominated loan, FCCD/CCD can't be construed on par with foreign currency loan for pur...
Chennai, Feb 21, 2025 By TII News Service
TP - Aaccceptance of terms of buyer on commercial considerations, becomes influence for purpose of Sec 92A(2)(i), if seller has no choice but to ...
Bengaluru, Feb 21, 2025 By TII News Service
TP - Outstanding dues beyond agreed credit period in case of assessee are separate international transaction, requires to be benchmarked separate...
Hyderabad, Feb 20, 2025 By TII News Service
I-T - Time limit prescribed for AO to pass assessment u/s 144C(13), shall be reckoned from date of original directions issued by DRP u/s 144C(5),...
Mumbai, Feb 20, 2025 By TII News Service
TP - Considerations which apply for issuance of Corporate Guarantee to AES are distinct from that of Guarantee provided by banks: ITAT ...
Mumbai, Feb 20, 2025 By TII News Service
I-T - Capital gain earned by non-resident assessee upon sale of shares /derivatives acquired prior to April 01, 2017 cannot be subjected tax in I...
Hyderabad, Feb 20, 2025 By TII News Service
TP - Aggregation transaction approach can be adopted only where, there exists close inter-linking between all transactions: ITAT...
Hyderabad, Feb 20, 2025 By TII News Service
I-T- Deduction u/s 35D pertaining to expenses incurred before commencement of business, rightly disallowed where assessee fails to provide adequa...
New Delhi, Feb 20, 2025 By TII News Service
I-T- Draft assessment order is invalid where it passed beyond the period of one month from receipt of directions from DRP: ITAT ...
New Delhi, Feb 19, 2025 By TII News Service
I-T - Assistance provided with respect to rules and regulations for clearance of customs frontiers, is not 'specialised knowledge' to render such...
Mumbai, Feb 19, 2025 By TII News Service
TP - Period of Sec 144C(13) can't be counted from end of month in which transfer pricing officer gives effect of direction of DRP u/s 144C(5): HC...
Bengaluru, Feb 19, 2025 By TII News Service
I-T - Consideration paid for purchase of software, cloud computing, cloud space hiring involving transfer of right to use software, is not royalt...
Ahmedabad, Feb 19, 2025 By TII News Service
I-T - Only because Tribunal has not dealt with merits of matter, same cannot be considered as information, so as to assume jurisdiction to issue ...
New Delhi, Feb 18, 2025 By TII News Service
TP - Market value of power supplied by State Electricity Board to industrial consumers should be construed to be market value of electricity: ITA...
Hyderabad, Feb 18, 2025 By TII News Service
I-T - Extended time of 12 months in terms of section 153(4) is available only in case, where reference u/s 92CA is made to TPO, but not in case o...
Mumbai, Feb 18, 2025 By TII News Service
INTL - Penalty u/s 271(1)(c) not tenable where change in assessee's status in relevant period from resident to non-resident, being debatable in n...
New Delhi, Feb 17, 2025 By TII News Service
TP - TPO can't compute ALP of assessee's international transactions as nil, merely because despite services availed from such transactions, asses...
New Delhi, Feb 17, 2025 By TII News Service
I-T - Assessee having no PE in India, in terms of Article 5 of India-Singapore tax treaty, washout receipts, being in nature of business income w...
Mumbai, Feb 17, 2025 By TII News Service
I-T - Once capital gains are considered as exempt under tax treaty, there would not be any occasion for seeking adjustment of brought forward sho...
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