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I-T- Compulsorily Convertible Debentures & Optionally Convertible Debentures, until conversion, retain essential characteristics of debt instruments akin to NCDs; ergo, qualify as debentures or bonds for tax purposes: ITAT (See Breaking News)

TP - Separate adjustment for receivables results in duplication, if economic effect of extended credit period is already subsumed in working capital adjustment: ITAT (See Breaking News)

I-T -Payments received by assessee will be business profits rather than royalty, where assessee merely organizes publicly available scientific information in a database & provides access to it, without transferring any copyright or proprietary rights to customers: ITAT (See Breaking News)

TP - TPO's approach in insisting upon daily/monthly working capital cycle data of third-party comparable is, unjustified if such data is admittedly not available in public domain: ITAT (See Breaking News)

TP- TNMM operates at net margin level & tolerates transactional differences; hence pricing mechanism or revenue scale alone cannot justify rejection of internal TNMM: ITAT (See Breaking News)

INTL - As is trite law, filing of Form 67 is directory and not mandatory; delay in filing Form 67 should not lead to disallowance of Foreign Tax Credit: ITAT (See Breaking News)

TP - Reference which was made to TPO after date when clause (i) of section 92BA was omitted by Finance Act, 2017, is not sustainable: ITAT (See Breaking News)

I-T - Reimbursement of salary paid to AEs which are merely in nature of reimbursements of seconded employee and does not include any element of income, does not attract TDS: ITAT (See Breaking News)

I-T - Final assessment order passed by AO merits to be quashed if it is not in conformity with DRP directions: ITAT (See Breaking News)

I-T - If allocation/attribution of income to PE is at arm's length, then no further ad-hoc attribution is required: ITAT (See Breaking News)

TP - While principle of res judicata does not apply to tax proceedings, the principle of consistency must be observed, especially where there is no change in facts or legal position: ITAT (See Breaking News)

TP - Provision for bad & doubtful debts is only accounting treatment and have no direct nexus to operating income: ITAT (See Breaking News)

TP - Working capital adjustment can't be denied merely due to absence of detailed working capital cycle data and adjustment should be granted based on average of opening & closing balances: ITAT (See Breaking News)

DTAA - Prior taxability of similar income in earlier years does not bar assessee's lawful claim for relief in current year, more so when there is no change in facts: ITAT (See Breaking News)

Netherlands to grow at 1.3% rate in 2025: OECD (See Brief)

TP - Corporate guarantee given by assessee on behalf of AE in absence of any expenditure being incurred by assessee, would not constitute international transaction within meaning of Sec 92B: ITAT (See Breaking News)

TP - Gross profitability margin may vary significantly over time, and hence, reliance on data of earlier years would not constitute reliable benchmark: ITAT (See Breaking News)

DTAA - Management support services do not make available any technical knowledge or skill to recipient; ergo, consideration therefor is not taxable as FTS under India-Singapore DTAA: ITAT (See Breaking News)

I-T - Amortization of capital subsidy in itself is not allowable as direct deduction u/s 80-IC, rather impact of capital subsidy is reflected in reduced "actual cost" of asset, leading to claim of lower depreciation: ITAT (See Breaking News)

I-T - If repair & maintenance of aircraft equipment provided by foreign assessee to Indian airline operators, did not involve transfer of technology, then receipts from said services are not taxable as FIS: HC (See Breaking News)

TP - If number of transactions are closely linked, then same should be treated as composite transaction and can be aggregated and construed as single transaction for purpose of determining ALP: ITAT (See Breaking News)

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