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TP - Transfer pricing adjustment made on account of corporate charges for technical, marketing and administrative support services availed from its AE, is not tenable where Assessee's transfer pricing study has over a long time been conducted using TNM method: ITAT (See 'Breaking News') SC Ruling in the KRIBHCO case: An Analysis (See 'TII Edit') I-T- According to guidelines issued by CBDT, safe harbour rates would apply only if assessee has opted for them and safe harbour rules don’t have retrospective application: HC (See 'Breaking News') DTAA - When rights to tax certain income, under applicable tax treaty provisions, are allocated to a residence jurisdiction, it is wholly immaterial whether or not source jurisdiction has right to tax said income: ITAT (See 'Breaking News') DTAA - Payment of consideration would be regarded as Fee for technical/Included Services only if the twin test of rendering services and making technical knowledge available at the same time is satisfied: ITAT (See 'Breaking News') TP - As clause (i) of section 92BA stands omitted & omission of such provision is to be construed as if it never existed, then no ALP is required to be determined for transaction with specified persons in section 40A(2)(b) of a domestic transaction: ITAT (See 'Breaking News') I-T - Assessment order issued without mentioning of DIN be treated as invalid: ITAT (See 'Breaking News') TP - It is fit case for remand where foreign exchange fluctuation loss adjustment is to be recomputed by TPO upon considering Profit Level Indicator from relevant details: ITAT (See 'Breaking News') TP - Company adopted as comparable for benchmarking purposes, merits being dropped as comparable, due to absence of data pertaining to its financials: ITAT (See 'Breaking News') I-T - Addition u/s 56(2)(vii)(b) is unwarranted, where difference between actual sale consideration & FMV determined by valuation officer is less than 10%: ITAT (See 'Breaking News') INTL - Evidences obtained from external sources & having critical bearing on outcome of subject matter, ought to have been admitted to reinforce overriding cause of substantial justice vis-a-vis technical considerations: ITAT (See 'Breaking News') INTL - First Appellate Authority is obligated to ensure that an effective opportunity is granted to the assessee for presenting its case and all evidences are taken into account while determining issue at hand: ITAT (See 'Breaking News') DTAA - Broadcasting Reproduction Right is different from copyright as defined in the Copyright Act: ITAT (See 'Breaking News')
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