Friday , December 8, 2023 |   05:46:18 IST
INTL TAXATION INTL MISC TP FDI LIBRARY VISA BIPA NRI
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NEWS FLASH
 
TP - Transfer pricing adjustment is unwarranted where tolerance band of the ALP adjustment falls within +/- 5% as per second proviso to Section 92C: ITAT (See 'Breaking News') TP -Transfer pricing adjustment framed on account of notional interest on receivables, is justified, where the assessee-company is found to not have incurred any debt: ITAT (See 'Breaking News') Energy crisis drives fall in tax levels in OECD countries I-T- Where assessee's claims of being a non-resident deserved to be accepted, his salary income from Sudan should be exmepted : ITAT (See 'Breaking News') I-T - Final assessment order passed without mentioning mandatory DIN is invalidated: ITAT (See 'Breaking News') TP - Final assessment order passed without incorporating the DRP's directions not valid: ITAT (See 'Breaking News') TP - Penalty imposed u/s 271(1)(c) rightly quashed where additions/disallowances based on which penalty was imposed, are themselves set aside: ITAT (See 'Breaking News') TP - RPM method is most appropriate for benchmarking of pure trading company involved in distribution activity without adding any value to purchased product: ITAT (See 'Breaking News') I-T - Power of revision u/s 263 is rightly exercised if AO in original assessment proceedings, omits to examine issue of license fee & royalty paid by Assessee to its holding companies during relevant period: ITAT (See 'Breaking News') TP - Turnover is relevant criteria for choosing companies as comparables in determining ALP in Transfer Pricing cases: ITAT (See 'Breaking News') I-T- CUP method can be adopted as most appropriate method in the case of the assessee owing to differences on account of volume, geography, functions performed and risks assumed : ITAT (See 'Breaking News') I-T- It is fit case for remand where re-assessment exercise omits to consider claim of Foreign Tax Credit, raised by the Assessee: HC (See 'Breaking News') TP - Resale Price Method incorrectly applied for benchmarking international transaction involving supply of military equipment: ITAT (See 'Breaking News') TP - If AO passes assessment order without receiving directions of DRP and merely relying on TPO's order giving effect to directions of DRP is bad in law: ITAT (See 'Breaking News') I-T - DRP directions issued without a Document Identification Number is invalid and deemed to have never been issued as per CBDT Circular No. 19 of 2019: ITAT (See 'Breaking News') Unraveling Complexity: MFN Clause and Its Tax Treaty Ramifications (See Guest Column in TIOL) I-T - Unless assessee's return is processed and decision taken by reasoned order, assessee would be justified in approaching for direction for refund: HC (See 'Breaking News') I-T - In absence of statutory provisions, retention of refund in anticipation of conclusion of DRP proceedings, and to give credit to this amount while giving-effect to orders thereafter cannot be accepted: HC (See 'Breaking News') TP - Time barred order passed by TPO merits to be quashed: ITAT (See 'Breaking News') Software rentals constitute Royalty: Pakistan SC's recent judgement (See TII Edit)
 
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TII BREAKING NEWS
 
TP - Transfer pricing adjustment is unwarranted where tolerance band of the ALP adjustment falls within +/- 5% as per second proviso to Section 92C:
TP -Transfer pricing adjustment framed on account of notional interest on receivables, is justified, where the assessee-company is found to not have incurred any debt:
I-T - Final assessment order passed without mentioning mandatory DIN is invalidated: ITAT
I-T- Where assessee's claims of being a non-resident deserved to be accepted, his salary income from Sudan should be exmepted : ITAT
< More News >
 
TII SPECIAL Nov 15, 2023
 
Tech-driven Tax Administration turning chummier towards taxpayers
By Pratap Singh, Pr CIT

THE success of a modern, progressive tax system hinges on two efficient wheels– Tax legislation with moderate tax rates and a dynamic tax administration. No fiscal reform in any tax jurisdiction can yield optimal results unless both the wheels are ‘greased' simultaneously to sprint together smoothly! In the recent years, India has also undertaken

 
TII EDIT Nov 27, 2023
 
Software rentals constitute Royalty: Pakistan SC's recent judgement
By D P Sengupta

IT is not often that we come across important international tax cases from Pakistan. However, on 8th September, 2023, the Pakistan Supreme Court has rendered an important verdict on the vexed question of source country taxation of software as royalty under the Pakistan-Nederland's tax treaty in favour of the Pakistan Revenue

 
BULLETIN BOARD
 
New Delhi, Nov 01, 2023
Govt notifies of Tax Information Exchange Agreement signed between Government of India and...
New Delhi, Nov 01, 2023
CBDT notifies a pension fund under Section 10(23FE) of Income Tax Act...
New Delhi, Sep 27, 2023
CBDT notifies form for audit or inventory valuation under Section 142(2A) of Income Tax Ac...
New Delhi, Sep 25, 2023
CBDT amends I-T Rules; inserts formula for computing fair market value of unquoted equity...
< More News >
 
TII BRIEF
 
Paris, Dec 06, 2023
Energy crisis drives fall in tax levels in OECD countries ...
Paris, Nov 30, 2023
OECD expects modest rise in economic growth in 2025 ...
Paris, Nov 24, 2023
Trade shrivels for G20 merchandise goods in Q3 ...
Paris, Nov 24, 2023
MNCs reporting low-profit even in high tax rate jurisdictions: OECD ...
Paris, Nov 21, 2023
GDP in OECD area up by 0.5% in Q3 ...
 
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