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NEWS FLASH

DTAA - Amount paid by Indian end users of software, as consideration to non resident supplier of software, does not amount to payment of royalty - TDS not to be deducted thereon: SC LB (See 'Breaking News')

I-T - Payment remitted by Indian distributors to non-resident for use of software is not royalty - No TDS obligation arises u/s 195: SC Larger Bench (Full judgement to be uploaded soon)

I-T - Income from cloud hosting services is not royalty within the meaning of explanation (2) to section 9(1)(vi) of the Act or India-US DTAA: ITAT (See 'Breaking News')

TP - Once impact of outstanding receivables on profitability was taken into account while making working capital adjustment, no further ALP adjustment is warranted: ITAT (See 'Breaking News')

DTAA - Capital gains arising to non-resident on sale of shares of Indian concern is liable to tax in Singapore only in accordance with treaty provisions: AAR (See 'Breaking News')

TP - Reference to TPO in case of specified domestic transactions mentioned u/s 92BA(i) is invalid, if said provision stands omitted by way of amendment: ITAT (See 'Breaking News')

TP - In determination of ALP under TNMM, Rule 10TA(k) providing for exclusion of foreign exchange gain from purview of operating revenue does not get attracted: ITAT (See 'Breaking News')

TP - Cost paid by taxpayer to AEs for implementation of SAP ERP system without any mark–up cannot be treated as NIL by applying benefit test: ITAT (See 'Breaking News')

Digital tax - US allows online businesses to be taxed wherever they do business - Safe harbour demand dropped

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TII BREAKING NEWS

New Delhi, Mar 02, 2021 By TII News Services

DTAA - Amount paid by Indian end users of software, as consideration to non resident supplier of software, does not amount to payment of royalty

Mumbai, Mar 02, 2021 By TII News Services

I-T - Income from cloud hosting services is not royalty within the meaning of explanation (2) to section 9(1)(vi) of the Act or India-US DTAA:

New Delhi, Mar 02, 2021 By TII News Services

TP - Once impact of outstanding receivables on profitability was taken into account while making working capital adjustment, no further ALP adjustment is warranted: ITAT

New Delhi, Mar 01, 2021 By TII News Services

DTAA - Capital gains arising to non-resident on sale of shares of Indian concern is liable to tax in Singapore only in accordance with treaty

< More News >

TII SPECIAL

Feb 19, 2021

World Needs A New Order To Avoid Covid-fired Debt Crisis

By Naresh Minocha

THE Covid-19 virus is turning out to be more lethal than dozens of Hydrogen Bombs. Leave aside for a while human tragedy reflected in the death of a few million & health issues faced by countless survivors. Think of pandemic-linked economic destruction including steep rise in unemployment and poverty.

Worry

View Previous Column >>

TII EDIT

Feb 11, 2021

Union Budget & International Tax

By D P Sengupta

BUDGET 2021 having taken place in exceptional times, a lot was expected from it, particularly from the point of view of mobilising additional revenue to support the expected additional expenditure plan of the Government of India. The OXFAM inequality report published just a few days back, added extra poignancy

View Previous Column >>

BULLETIN BOARD

New Delhi, Jan 29, 2021
CBDT appoints Ms Shilpi and Mr Ashish Chandra and OSD in FT&TR Division...

New Delhi, Jan 16, 2021
CBDT issues detailed Circular on remuneration to eligible investment fund manager u/s 9A(3...

Mumbai, Jan 12, 2021
Foreign Exchange Management (Export of Goods and Services) (Amendment) Regulations, 2021...

New Delhi, Dec 18, 2020
Filling up the post of officers at the level of Under Secretary/DCIT(OSD) in FT&TR Divisio...

< More News >

TII BRIEF

Paris, Feb 23, 2021
Croatia, Malaysia finalise OECD's BEPS multilateral tax treaty ...

Paris, Feb 23, 2021
Sea transport is primary route for counterfeiters: OECD...

Paris, Feb 23, 2021
G20 merchandise trade - Q4 of 2020 shows hearty recovery...

Geneva, Feb 20, 2021
WTO working group on MSMEs reflects on topics for 2021 workplan ...

Washington, Feb 19, 2021
World Bank names Senegal's Diop as head of IFC private-sector arm ...

More News >>

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