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DTAA - Profits of non-resident assessee would be taxable only in its resident state, and is eligible for tax withholding certificate in identical...
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...
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 ...
TP - Outstanding dues beyond agreed credit period in case of assessee are separate international transaction, requires to be benchmarked separate...
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),...
TP - Considerations which apply for issuance of Corporate Guarantee to AES are distinct from that of Guarantee provided by banks: ITAT ...
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...
TP - Aggregation transaction approach can be adopted only where, there exists close inter-linking between all transactions: ITAT...
I-T- Deduction u/s 35D pertaining to expenses incurred before commencement of business, rightly disallowed where assessee fails to provide adequa...
I-T- Draft assessment order is invalid where it passed beyond the period of one month from receipt of directions from DRP: ITAT ...
I-T - Assistance provided with respect to rules and regulations for clearance of customs frontiers, is not 'specialised knowledge' to render such...
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...
I-T - Consideration paid for purchase of software, cloud computing, cloud space hiring involving transfer of right to use software, is not royalt...
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 ...
TP - Market value of power supplied by State Electricity Board to industrial consumers should be construed to be market value of electricity: ITA...
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...
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...
TP - TPO can't compute ALP of assessee's international transactions as nil, merely because despite services availed from such transactions, asses...
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...
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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