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OECD headline inflation on slide despite rising foods prices (See Brief) DTAA - Payment to Non-resident for providing Independent personal services, is taxable in India only if he has fixed base in India or he stayed for more than 183 days in India: ITAT (See Breaking News) DTAA - Delay in filing Form 67 does not preclude assessee from claiming Foreign Tax Credit as per DTAA provisions; right to claim FTC is vested right: ITAT (See Breaking News) TP - If loan was provided by third party lender, but AE provides explicit or implicit guarantee to such lender or deposits corresponding amount of funds with lender, such debt shall be deemed to have been issued by AE: ITAT (See Breaking News) TP - Risk adjustment disallowed where no basis is found for granting it, more so, where assessee fails to provide credible evidence to distinguish its risk profile that of the comparable companies: ITAT (See Breaking News) I-T- Jurisdictional issues can be raised at any stage, especially when they go to the root of the matter: ITAT (See Breaking News) I-T - Payments made for marketing related services and use of trademark etc which is incidental to main objective cannot be categorised as royalty or FTS: HC (See Breaking News) I-T - If assessee had filed its objection before DRP, albeit not intimated due to glitches in website, NFAC ought to have awaited outcome of DRP proceedings and could not have proceeded to pass assessment order: HC (See Breaking News) I-T - Not mentioning pendency of writ cannot be construed as failure to disclose material fact, which would render declaration made by assessee non-est u/s 91(5)(a) of Finance (No.2) Act 2024 or otherwise invalid: HC (See Breaking News) TP - Comparable company merits being dropped where it is functionally dissimilar to the assessee and segmental data is lacking: ITAT (See Breaking News) TP - Entity exclusively engaged in ITES segment is not comparable to entity engaged in distribution activities: ITAT (See Breaking News) TP - CUP method shall be applied for benchmarking, in case of comparison between ratio of Intra Group Services payment to sales of assessee with ratio of similar expenses to sales of comparables: ITAT (See Breaking News) I-T - Assessment passed in name of non-existent company is bad in law: ITAT (See Breaking News) I-T - Proceedings u/s 263 cannot be initiated for purpose of making fishing/roving enquiries w.r.t. variety of issues only with objective of substituting his views with that of AO: ITAT (See Breaking News) TP - If assessee is not charging interest on account of delay in receivable either from its AEs or from non-AEs, no adjustment of interest in respect of overdue receivable can be made: ITAT (See Breaking News) TP - Comparable company merits being excluded where its business model differs considerably from that of the assessee & which has a brand value different from that of assessee: ITAT (See Breaking News) DTAA - Merely having PE in India is not sufficient to exclude applicability of Article 11(2) and invoke Article 11(6) r/w Article 7(1) of India-Japan DTAA: ITAT (See Breaking News) I-T - One-time benefit received by retired cricketor from Board of Control for Cricket in India in recognition of his past services to Indian cricket, is eligible for exemption u/s 56(2)(vii) and not subject to tax: ITAT (See Breaking News) TP - Segmented information shall be used for benchmarking trading activity involving purchase of finished goods and manufacturing activity involving purchase of raw materials and export of manufactured goods: ITAT (See Breaking News) Trump's Tariff Tantrums (See 'TII Edit')
 
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