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DTAA -Revenue earned by assessee-company from supply of software & maintenance thereof, cannot be deemed to be Royalty as per I-T Act & India-UK ...
I-T- Assessee entitled to deduction on amount paid to non-resident for expenses incurred, considering that recipient declares amount so received,...
TP - Department's premise of Royalty being paid by the assessee-company to its own self, where such a payment be made to a holding company, is wh...
I-T- As per trite law, an assessee cannot be expected to deduct tax at source from payments that became taxable owing to retrospective amendment:...
DTAA - consideration received for provision of Managerial Services, cannot be deemed to be Royalty or taxed as such, where no transfer of knowled...
TP - Where TPO's report is limited to determination of ALP only, then the AO cannot travel beyond determination of ALP: ITAT...
I-T- Once profit from business increases, it will correspondingly increase amount of deduction claimed u/s 10A; even if business profit is increa...
DTAA - Lease rental income earned by assessee cannot be treated as royalty under DTAA or I-T Act: ITAT...
I-T- Re-imbursement of costs incurred by Indian arm of foreign company towards certain expenses incurred by the former on the latter's behalf, ca...
I-T-Since extended time limit of 12 months is not available in case of Non-Resident as per section 153(4), AO ought to have completed assessment ...
TP - Adjustment of forex loss is not extraordinary in nature, where assessee is engaged in exports & earns in forex & where any resultant gains o...
I-T - Taking consistent view, C G VAX Software & Exports Ltd cannot be considered for inclusion in list of comparables : ITAT...
DTAA - Non fulfillment of any procedural requirement, cannot in any way, debar an assessee from any claim or benefit under the law to which he is...
I-T- Prior approval for search asssessment u/s 153D is mandatory; must be accorded after due consideration of facts; must not be mechanically gra...
I-T- Payables and receivables are two sides of same point and both have to be taken together and only net amount can be adjusted as separate tran...
I-T- Interest u/s 234B cannot be imposed where the assessee already paid the tax demanded within the time limit of 30 days: ITAT ...
https://taxindiainternational.com/case_lawDesc.php?qwer43fcxzt=MTQyMDc= ...
I-T- Appeal to CIT(A) will lie against amendment of TP order passed u/s. 92CA(3) for purpose of rectification of mistake apparent on record : ITA...
I-T- In light of certain subsequent developments, nothing survives to adjudicate hence appeal can be disposed of : HC ...
I-T - Once corporate guarantee fee is worked out on basis of third-party prevailing market rate, there is no basis or justification for further m...
 
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