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DTAA - provision of technical services does not per se suffice for consideration for services to qualify as Fees for Included Services: ITAT (See 'Breaking News') DTAA - Make available entails transmitting technical knowledge such that service recipient derives enduring benefit & utilizes such technical knowledge or skill in future without aid from service provider: ITAT (See 'Breaking News') DTAA - That provision of service may require technical input by the person providing the same, it does not per se mean that technical knowledge, skills, is made available to service recipient: ITAT (See 'Breaking News') INTL - Once clinical trial expenses incurred outside approved R&D facilities, are approved by prescribed authority, then assessee is entitled to claim deduction u/s 35(2AB): ITAT (See 'Breaking News') TP - Functional dissimilarity is sufficient for excluding comparables for purposes of benchmarking: HC (See 'Breaking News') TP - Once working capital adjustment is granted to assessee, there is no need for further imputation of interest on outstanding receivables at end of year: HC (See 'Breaking News') INTL - Final assessment order merits being quashed where it is largely a copy of draft assessment order & omits to consider directives given by DRP: ITAT (See 'Breaking News') TP - If TPO fails to answer issue of international transactions bearing in mind Explanation (i)(c) of Section 92B, no addition of arms' length interest is warranted on account of delayed receivables: HC (See 'Breaking News') I-T- For activity of assessee to be in charitable in nature, services rendered must commensurate with benefit that may arise to such poor people : ITAT (See 'Breaking News') I-T - Fees received by the foreign branch of banking company for extending credit line to account holder outside India, would not be taxable in India: HC (See 'Breaking News') TP - Once ALP principle is satisfied, no further profit is attributable even if there is PE in India: HC (See 'Breaking News') TP - Additions on account of Advertising, Marketing & Promotional expenses are unwarranted where no evidence exists to suggest arrangement between Indian assessee & its AE abroad: HC (See 'Breaking News') TP - There is no thumb rule of applicability of LIBOR plus basis points, considering that it depends upon various factors: ITAT (See 'Breaking News') DTAA - India-Ireland treaty exempts aircraft leasing activity from taxation; revenue arising therefrom not treatable as royalty; provisions of DTAA supersede those of I-T Act insofar as they are beneficial to assessee: HC (See 'Breaking News')
 
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