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TP - Entity which undertakes R&D activities and own intellectual property in form of technology and brand, cannot be compared with software developer: ITAT (See Breaking News)

DTAA - Capital loss incurred under I-T Act r/w Art 13(5) of India-Ireland DTAA can't be set off against short term capital gain derived from sale of rights of entitlement: ITAT (See Breaking News)

TP - AO must provide opportunity of hearing to assessee before transfering his case to TPO, if there is potential of income arising on determination of ALP of international transaction/ specified domestic transaction: HC (See Breaking News)

TP - Comparable company be dropped, where a prior order recalling the inclusion of this company is final and binding: ITAT (See Breaking News)

TP - If ITAT has rightly decided ground pertaining to upward adjustment of international transaction of payment of guarantee fees to AE in favour of Assessee, no writ interference is warranted: HC (See Breaking News)

I-T- Re-assessment proceedings are invalid where reasons recorded by AO are issued after issuing re-assessment notice: ITAT (See Breaking News)

I-T - Role of remitter banker is simply to follow extant procedure and to deduct Tax at source as prescribed under statute: ITAT (See Breaking News)

I-T - If payroll of assessee is in India during assignment period but entire salary reported in Form No.16 is cross charged to Singapore entity, then AO must examine no.of days assessee had worked in India before deciding its taxability: ITAT (See Breaking News)

I-T - If assessee is not having any PE in India and is covered by India US DTAA and MOA, nature of services rendered by assessee on account of which received remunerations can't be described as FIS: ITAT (See Breaking News)

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