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TP - If conditions as specified u/s 92C(3) stands satisfied, then TPO is well within his rights to proceed with ALP adjustment: HC (See Breaking News) I-T - If communication by I-T Authorities did not specify conclusively entitlement of assessee to refund claim, it can't be considered as final determination culminating in final order u/s 237 admitting entitlement to refund of excess DDT: HC (See Breaking News) TP - Bright line test is not valid method for determination of AMP adjustment, where payment of commission is fully dependent upon sales achieved and has nothing to do with product building exercise: ITAT (See Breaking News) DTAA - Benefit of exclusion of time by virtue of Explanation (ix) of Sec 153B would be available only if reference was made in terms of Indo-Swiss DTAA: HC (See Breaking News) DTAA - LTCG from grandfathered share transactions is exempt under Article 13(4) of India-Mauritius DTAA; does not constitute income under I-T Act for purposes of loss set-off u/s 70(2) & 70(3): ITAT (See Breaking News) DTAA - As per settled legal position, where the DTAA is silent on intra- head adjustments, the beneficial provisions of the domestic law must prevail: ITAT (See Breaking News) TP - Benefit test cannot be applied in case of intragroup services, if it was project specific services: ITAT (See Breaking News) TP - If impact of credit period was factored in Working Capital Adjustment while determining Arm's Length Price, then no further adjustment was required for interest on receivables: ITAT (See Breaking News) TP- Condition of make available is not satisfied for services when provided by assessee did not enabled AEs to apply technology independently, on conclusion of yearly contract: ITAT (See Breaking News) DTAA - Simply booking of freight as agent does not imply that it is empowered to conclude any contracts, and hence, it cannot be treated as dependent agent PE: ITAT (See Breaking News) OECD unemployment rate remains stable at 4.9% in March (See Brief) I-T - Receipt from passenger services can't be treated as FTS, since no technology is made available to National Aviation Company and services are rendered using software supported by data centre of assessee in USA: ITAT (See Breaking News) I-T- Additions framed u/s 68 r/w Section 69C not tenable when there is no direct nexus between assessee & alleged manipulation of stock entries: ITAT (See Breaking News) INTL -Re-assessment is invalid where basis therefor is factually incorrect and is based on erroneous assumption of facts: ITAT (See Breaking News) Real household income grew in 2024: OECD (See Brief) I-T - If Central Government has entered into agreement with foreign country for avoidance of double taxation, then in relation to Assessee to whom such agreement applies, provisions of Act shall apply to extent they are more beneficial: HC (See Breaking News) DTAA - Conducting background checks & verification of testimonials do not involve use of technical knowledge or skill as required to be considered royalty: ITAT (See Breaking News) Export curbs on critical raw materials sharply rising: OECD (See Brief) I-T- Notice u/s 148, unsustainable where it was issued 8 days before expiry of extended limitation period, which leaves assessee with very little time to file reply thereto: ITAT (See Breaking News)
 
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