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TP - Once ITAT set aside assessment order, demand arising from said order stood extinguished and it was duty of AO to delete outstanding demand from portal of assessee: HC (See Breaking News)

TP - Assessee having factored in impact of receivables on working capital and thereby on its pricing vis-a-vis comparables, further adjustment based on outstanding receivables amounts to re-characterization of transaction: ITAT (See Breaking News)

TP - In absence of notice issued u/s 92D(3) requiring assessee to furnish any information in respect of international transaction entered into by assessee, no penalty can be levied u/s 271G: ITAT (See Breaking News)

TP - Final assessment is required to be passed by AO within one month from date of receipt of order form end of the month, in which TPO's order after DRP's direction, was received by AO: ITAT (See Breaking News)

TP - TPO should adopt rates for transaction of notional interest on outstanding receivables, as per rate agreed under Bilateral APA with AE and compute ALP adjustment accordingly: ITAT (See Breaking News)

I-T - Reimbursement of expenses can't be regarded as income in hands of payee/recipient: ITAT (See Breaking News)

CBDT clarifies on application of PPT Provision under DTAAs (See Brief)

TP - AMP expenditure incurred by assessee for brand owned by its AE would not constitute international transaction, in absence of any arrangement for benefit of brand owner: HC (See Breaking News)

I-T - Once final assessment order was made by AO and same was subject matter of appeal before CIT(A), then DRP would become functus officio and have no powers to issue directions for making yet another assessment order: HC (See Breaking News)

I-T - Taxability of foreign remittances and obligation to withhold TDS on management fee and testing charges, merits fresh adjudication, if AO has not carried out proper enquiry of documentary evidences: ITAT (See Breaking News)

TP- When AO could not have directly make any changes in final assessment order after directions of DRP, then PCIT can't make any changes, so as to circumvent provisions of Sec 144C(13): ITAT (See Breaking News)

TP - Where including management support services in cost base could not result in erosion of the tax base, then additions on account of transfer pricing adjustment need not be made: ITAT (See Breaking News)

I-T - Payments made for mere transfer of copyrighted article, can't be held to be in nature of royalty: ITAT (See Breaking News)

I-T - Assessment order passed in case of non-existing entity can't be sustained: ITAT (See Breaking News)

I-T- Assessee cannot raise objections against final assessment order after failing to comply with statutory requirement for filing objections within prescribed time limit: ITAT (See Breaking News)

I-T - Salary received by non-resident assessee for services rendered outside India, though received in India, is not taxable as per provisions of section 9(1)(ii): ITAT (See Breaking News)

I-T - In absence of PE, income non-resident accrued outside India is neither liable to be assessed as business profit of payee nor as royalty: ITAT (See Breaking News)

TP - While determining ALP of international transactions under transfer pricing regulations, aggregation of transactions is often necessary provided they are closely linked functionally or economically: ITAT (See Breaking News)

I-T - Receipt towards fabrication of bushings can't be treated as FTS, if they pertain to charges for refurbishment of bushings carried out at plant in Singapore which were in nature of manufacturing activity: ITAT (See Breaking News)

I-T - Mere rendering of services is not roped into FIS unless person utilizing such services is able to make use of technical knowledge for his own benefit in future: ITAT (See Breaking News)

INTL - Disallowance of salary expenses u/s 40(a)(ia) is invalid where the DRP had not considered additional evidence filed by assessee: ITAT (See Breaking News)

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