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NEWS FLASH   I-T - Exercising substantial control over day-to-day operations of hotels, going well beyond mere advisory role, thereby qualify Hyatt International as Permanent Establishment: SC (See Breaking News) I-T - Existence of Permanent Establishment is sufficient to attract tax liability for foreign entity in India, even in absence of exclusive possession of fixed place of business: SC (See Breaking News) I-T -Temporary or shared use of premises, when combined with administrative or operational control, is adequate to establish PE, thereby triggering income tax liability in India: SC (See Breaking News) DTAA - Mere availing of services that may require technical expertise would not qualify consideration paid for such services as FTS: HC (See Breaking News) TP - TPO is not authorized to challenge commercial prudence or benefit derived from services in absence of substantive contrary evidence: ITAT (See Breaking News) TP - Data under CUP method is not available and data of margins under TNMM is readily available, then it would be appropriate to apply TNMM method as Most Appropriate Method: ITAT (See Breaking News) I-T - Non-resident bank can claim set off of current year business loss of PE against interest income earned from Indian customers, if treaty itself provides for taxability of income in terms with Income Tax Act: ITAT (See Breaking News) I-T - Payments made to non-resident entities towards testing services are liable for deduction of tax at source u/s 195, if testing did not involve any transfer of technical knowledge: ITAT (See Breaking News) INTL -Internal procedural variations or user functionalities within ITBA system cannot override statutory timelines: ITAT (See Breaking News) INTL - Where no hierarchy for set-off is prescribed under the Act, therefore, assessee is entitled to adopt a beneficial order of set-off of capital losses: ITAT (See Breaking News) INTL - Corporate guarantee falls within the scope of international transactions under the Act & in keeping with settled precedent, corporate guarantee fee be computed at 0.5%: ITAT (See Breaking News) I-T - Any legal contention or even claim would be permissible to be raised for first time before appellate authority or Tribunal when facts necessary to examine such contention or claim are already on record: HC (See Breaking News) I-T - Provisions of DTAA would override provisions of Income Tax Act if provisions of DTAA are more beneficial to assessee: HC (See Breaking News) DTAA - Receipts for satellite data transmission services do not qualify as royalty either under the Act or DTAA & are not taxable in India in absence of permanent establishment: ITAT (See Breaking News) DTAA - As per Article 12(4) of India-USA DTAA, for a service to be classified as Fees for Included Services, it must not only be technical or consultancy in nature but also make available technical knowledge, skill, know-how, or processes: ITAT (See Breaking News)   SIGN IN   Username Password Forgot Password   Home >> Case Law Details     Member Login         Username :   Password :        Forgot Password

INTL TAXATION INTL MISC TP FDI LIBRARY VISA BIPA NRI TII DTAA Circulars (I-T Act, 1922) Limited Treaties Other Treaties TIEAs Notifications Circulars Relevant Sections of I-T Rules,1962 Instructions Administrative Orders DRP Panel I-T Act, 1961 MLI Relevant Portion of I-T Act,1922 GAAR MAP OECD Conventions Draft Guidelines DTC Bill Committee Reports FATCA Intl-Taxation Finance Acts Manual on EoI UN Model Taxation Miscellaneous Cost Inflation Index Union Budget Information Security Guidelines APA Annual Report APA Rules Miscellaneous Relevant Sections of Act Instructions Circulars Notifications Draft Notifications Forms TP Rules APA FAQ UN Manual on TP Safe Harbour Rules US Transfer Pricing FEMA Act Exchange Manual Fema Notifications Master Circulars Press Notes Rules FDI Circulars RBI Circulars Reports FDI Approved RBI Other Notifications FIPB Review FEO Act INTELLECTUAL PROPERTY CBR Act NBFC Report Black Money Act PMLA Instruction PMLA Bill FM Budget Speeches Multimodal Transportation Vienna Convention EXIM Bank LoC Manufacturing Policy FTDR Act, 1992 White Paper on Black Money Posting Policy PMLA Cases Transfer of Property MCA Circular Limitation Act Type of Visa SSAs EPFO Acts FAQs Rules Guidelines Tourist Visa Notifications Arbitration Model Text Agreements Relevant Portion of I-T Act I-T Rules, 1962 Circulars MISC Notification About Us Contact Us     A Taxindiaonline Website. Copyright © 2010-2025 | Privacy Policy | Taxindiainternational.com Pvt. Ltd. OPC All rights reserved. TIOL GROUP WEBSITES