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INTL TAXATION INTL MISC TP FDI LIBRARY VISA BIPA NRI
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TP - Company which has negative margins and abnormal financial fluctuations is unsuitable for being adopted as comparable company: ITAT (See Breaking News) TP - If TPO himself has accepted TNNM as most appropriate method for determining ALP in subsequent year, then supplementary TP analysis submitted by assessee ought to have been considered for purpose of determining ALP: ITAT (See Breaking News) CBDT expands scope of safe harbour rules (See Brief) TP - If intra-group services utilized by assessee are supporting core activities of assessee, there is no infirmity in assessee adopting TNMM as most appropriate method: ITAT (See Breaking News) TP - Statutory procedure mandated u/s 144C can't be bypassed by merely mentioning name of assessee as amalgamated entity with its former name and name of amalgamating company: ITAT (See Breaking News) I-T - AO must examine if management fees is in nature of FTS or not, before making disallowance of payments made to overseas parties for services rendered by them, which did not have PE in India: ITAT (See Breaking News) Debt markets in Emerging economies grow to USD 3 trillion in 2024: OECD (See Brief) I-T - If necessary requirements to claim benefit of MFN clause does not get satisfied, no treaty benefit can be claimed on dividend income: ITAT (See Breaking News) I-T - Merely because AO has not given elaborate reasoning and findings, does not lead to conclusion that order of AO is erroneous for want of inquiry: ITAT (See Breaking News) TP - In absence of availability of price of electricity in open market, best alternative available with TPO is to benchmark transactions in accordance with computation of ALP as mentioned u/s 92C r.w. Rule 10B: ITAT (See Breaking News) The Trump Card (See TII Edit) TP - For those outstanding receivables that fall out of working capital adjustment pertaining to year under consideration, rate of interest to be charged must be LIBOR + 300 basis points: ITAT (See Breaking News) TP - Reduction for purchase price adjustment can only be done to cost of goods sold/operating cost and not to operating revenue: ITAT (See Breaking News) TP - Merely on assumption of robust research & development facility of assessee with regard to some products developed in India, compensation under technology transfer agreement with non-AE can't be distinguished: ITAT (See Breaking News)
 
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