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NEWS FLASH

I-T - Denying of FTC due to procedural delay in filing of Form 67 goes against DTAA's objectives: ITAT (See Breaking News)

I-T - If transactions between non-resident assessee and its Indian AE is found to be at Arm's Length in transfer pricing adjustment, no further attribution can be made to PE of assessee: HC (See Breaking News)

I-T - Application for revision u/s 264 can be preferred by assessee who makes suo motu disallowance in its return, under bonafide yet mistaken belief that same was liable to be offered for taxation: HC (See Breaking News)

TP - Final assessment order merits being sustained, where it is found to be passed within the prescribed time limit: ITAT (See Breaking News)

TP - Comparable companies merit being excluded where functionally different from assessee & also different on account of having undergone extraordinary events like mergers & acquisitions: ITAT (See Breaking News)

TP - If actual difference of credit when sales are made by AE to related party, is much less than credit period when sales were made by assessee directly to related party, no ALP adjustment is warranted: ITAT (See Breaking News)

TP - Bright line test is no basis to determine ALP adjustment in case of AMP expenses: ITAT (See Breaking News)

I-T - Fee received towards administrative support services, will not qualify as FTS under treaty provisions: ITAT (See Breaking News)

I-T - If software itself was not taxable, then training & related activities concerned with utilization and installation cannot be held to be FTS: ITAT (See Breaking News)

TP - Merely because assessee has failed to prove any benefit from services received by AE, disallowances cannot be made by TPO: ITAT (See Breaking News)

TP - If delay in furnishing requisite details was attributable to 'reasonable cause', then same can't be brushed aside by TPO for levying penalty u/s 271G: ITAT (See Breaking News)

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