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TP - Turnover is relevant criterion for choosing companies as comparable companies in determination of ALP in transfer pricing cases: ITAT (See Breaking News)

I-T - If 'assets on free of cost basis' are provided by AE to assesse for carrying out assessee's work, and assesse is remunerated by considering depreciation in cost basis as per APA, such assets are not taxable u/s 28(iv): ITAT (See Breaking News)

I-T - Valuation report is required to be given of property as on date of its transfer, and valuation given on subsequent occasion will not be counted for purpose of capital gain: ITAT (See Breaking News)

I-T-Software license fees cannot be deemed to be royalty, considering that the make available clause is not satisfied: ITAT (See Breaking News)

I-T - Mere allegation of AO that non-disallowance of payment to non-resident without TDS, is wilful act of assessee in order to reduce its taxable income, is not sufficient to initiate reopening: ITAT (See Breaking News)

I-T- Additions u/s 69 invalid where assessee clearly discharges onus by explaining source & nature of such investment & the source of funds for such investment: ITAT (See Breaking News)

TP - Mark-up charged by AE for rendering of services should be allowed while determining ALP in international transaction: ITAT (See Breaking News)

TP - Assessee can claim deduction u/s 35DD for second year of amalgamation expenditure, despite time limit for filing revised return having lapsed: ITAT (See Breaking News)

TP - Interest should not be imputed on outstanding receivables in case of debt-free company, where working capital adjustment is already granted: ITAT (See Breaking News)

The Billionaire tax debate (See TII Edit)

DTAA - Receipts of non-resident company for provision of advertisement space is not chargeable to tax in India as 'royalty', in absence of transfer of any 'right to use': ITAT (See Breaking News)

I-T - Vague notice issued u/s 274 r/w/s 270A without specifying any particular limb or sub-clause for levying proposed penalty, merits deletion: ITAT (See Breaking News)

INTL - Foreign Tax Credit cannot be denied to assessee without allowing proper oppportunity of hearing, solely on grounds of late filing of Form No 67: ITAT (See Breaking News)

DTAA - As per settled position in law, income from services provided to an Indian payer is taxable in India: ITAT (See Breaking News)

I-T - If assessee has proved source of investment in share application money of foreign entity, and also explained source of source of funds, then no addition is warranted u/s 68: ITAT (See Breaking News)

I-T - If assessee has remained in India in last four years for more than 365 days and in relevant previous year for more than 182 days, then only he shall be treated as non-resident: ITAT (See Breaking News)

I-T - Income accrues at place where title to goods passes to buyers on payment of price: ITAT (See Breaking News)

DTAA - Merely because non-resident entity which had no PE in India, had applied for lower tax deduction certificate u/s 197, that in itself is no basis for imposing tax liability on its business receipts u/s 44BB: ITAT (See Breaking News)

DTAA - Tax demand cannot be raised against assessee was non resident of India in relevant period & who offered income for tax & paid tax thereon in foreign country: ITAT (See Breaking News)

I-T - Expenses exclusively incurred for Indian PE by foreign head office, which are not in nature of overheads, has to be excluded from purview of Sec 44C: ITAT (See Breaking News)

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