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INTL TAXATION INTL MISC TP FDI LIBRARY VISA BIPA NRI
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TP - Benefit of working capital adjustment if calculated on scientific basis can be allowed when computing ALP of international transaction: ITAT (See 'Breaking News') TP - Brand value & endurance to extraordinary events during relevant previous years calls for exclusion of such comparable during benchmarking: ITAT (See 'Breaking News') I-T - Merely because Indian PE deducted TDS when making payments to parent company abroad, latter's obligation to disclose such income through valid return does not cease: HC (See 'Breaking News') India-Portugal DTAA - New Article 26 inserted relating to exchange of information (See 'Notification' in 'Intl Taxation') TP - Adopting comparables without examining their audited financial statements & FAR analysis calls for re-adjudication of matter: ITAT (See 'Breaking News') TP - Rate of commission charged from overseas AEs for rendering financial guarantee needs no interference if decided in consonance with directions of Jurisdictional Writ Court: ITAT (See 'Breaking News') TP - Dispute relating to pairing of comparables based on FAR analysis of profit margins & risk adjustments for determining ALP does not warrant writ interference: HC (See 'Breaking News') TP - Mere dissatisfaction with factual findings of ITAT regarding selection of comparables after application of quantitative/qualitative filters cannot be contested u/s 260A: HC (See 'Breaking News') TP - Transactions related to 'Bottled in India Scotch' & 'Indian Made Foreign Liquor' cannot be clubbed merely because both are manufactured & processed in same plant: ITAT (See 'Breaking News') I-T - Penalty is unsustainable where quantum addition upon which such penalty is based is itself set aside: ITAT (See 'Breaking News') I-T - Dispute relating to exigibility to or exemption from taxation under I-T Act should not be decided by Appellate authority in summary manner: ITAT (See 'Breaking News') I-T - Dispute relating to receipt of income tax refund needs to be resolved before computation of interest chargeable u/s 234D: ITAT (See 'Breaking News') TP - Broad functional dissimilarity is no ground for exclusion of comparables, unless it fails to satisfy necessary other filters adopted for purposes of benchmarking: ITAT (See 'Breaking News') TP - Validity of reassessment should be examined based on 'reasons for reopening' alone & not any supplementary material: ITAT (See 'Breaking News')
 
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TP - Benefit of working capital adjustment if calculated on scientific basis can be allowed when computing ALP of international transaction: ITAT...
I-T - Merely because Indian PE deducted TDS when making payments to parent company abroad, latter's obligation to disclose such income through va...
TP - Brand value & endurance to extraordinary events during relevant previous years calls for exclusion of such comparable during benchmarking: I...
TP - Adopting comparables without examining their audited financial statements & FAR analysis calls for re-adjudication of matter: ITAT...
TP - Rate of commission charged from overseas AEs for rendering financial guarantee needs no interference if decided in consonance with direc...
TP - Dispute relating to pairing of comparables based on FAR analysis of profit margins & risk adjustments for determining ALP does not warra...
TP - Mere dissatisfaction with factual findings of ITAT regarding selection of comparables after application of quantitative/qualitative filt...
TP - Transactions related to 'Bottled in India Scotch' & 'Indian Made Foreign Liquor' cannot be clubbed merely because both are manufactured ...
I-T - Penalty is unsustainable where quantum addition upon which such penalty is based is itself set aside: ITAT ...
I-T - Dispute relating to exigibility to or exemption from taxation under I-T Act should not be decided by Appellate authority in summary manner:...
I-T - Dispute relating to receipt of income tax refund needs to be resolved before computation of interest chargeable u/s 234D: ITAT...
TP - Validity of reassessment should be examined based on 'reasons for reopening' alone & not any supplementary material: ITAT...
TP - Broad functional dissimilarity is no ground for exclusion of comparables, unless it fails to satisfy necessary other filters adopted for pur...
TP - Transactions between Indian entity & its overseas AE should be treated at arm's length, if rate of interest charged by AEs for delayed payme...
I-T - Upon doubt regarding taxability of payments made to overseas concern for purchase of software, application must be filed u/s 195(2) instead...
DTAA - Tax Residency Certificate constitutes sufficient evidence to accept status of residence as well as beneficial ownership when seeking treat...
TP - Mere dissatisfaction with factual findings regarding inclusion/exclusion of comparables after applying quantitative/qualitative filters cann...
TP - Dispute relating to adoption of most appropriate methods of benchmarking for arriving at ALP does not amount to substantial question warrant...
I-T - Omission to withhold taxes on overseas payments made for purchasing software attracts no disallowance u/s 40(a)(i) if such software facilit...
DTAA - Consideration received by German individual for rendering independent personal services to Indian company, are covered by Article 14 of In...
 
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