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DTAA - China Development Bank is financial institution wholly owned by Government of China & thus qualifies for benefits under Article 11(3) of India-China DTAA; India-based assessee cannot be deemed in default for failing to deduct tax u/s 195 on interest payments made to the bank: ITAT (See 'Breaking News') Better design of tobacco taxation needed to reduce consumption in Latin America: OECD (See Brief) INTL - As per settled position in law, Service Tax component does not form part of the receipt for computation of income as per section 44BB: ITAT (See 'Breaking News') DTAA - Non-residents are required to pay tax only on income received, deemed receivable, accrued or deemed accruable in India: ITAT (See 'Breaking News') DTAA - Stock option perquisites received by non-resident assessee for services provided outside India, cannot be included in total income for taxation in India: ITAT (See 'Breaking News') Attribution of Profit to a Permanent Establishment when globally the enterprise is in a loss (See TII Edit) TP - Rule 10AB does permit determination of ALP by simulating price that would have been charged in similar uncontrolled transactions under similar circumstances: HC (See 'Breaking News') I-T - Tax credit can't be denied where interpretation of residence country about applicability of treaty provision is not same as that of source jurisdiction, and yet source country had withheld taxes: ITAT (See 'Breaking News') TP - As per settled position in law, 0.5% commission on corporate guarantee is reasonable ALP: ITAT (See 'Breaking News') TP - Assessment order is invalidated where it is passed beyond the limitation period & where no extension of limitation period has been provided: ITAT (See 'Breaking News') TP - TPO not required to examine efficacy of commercial transactions & TPO's role is confined to determining price or value of transactions on arm's length basis: HC (See 'Breaking News') TP - As per settled position in law, adjustments to book profits should only be made as specified by the law: HC (See 'Breaking News') I-T- Once subsidiary company has been remunerated by holding company for commission activities on arm's length basis, no further attribution of profit is required: HC (See 'Breaking News') INTL - Final order barred by limitation where passed beyond 30-day statutory period for passing order, following directions being issued by DRP: ITAT (See 'Breaking News') TP - If assessee's foreign AE was not used as tested party during benchmarking, then status quo shall be maintained in all A.Ys, unless change in facts: HC (See 'Breaking News') INTL - Hardship allowance constitutes a capital receipt & is exempt from taxation as income: ITAT (See 'Breaking News')
 
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