CBDT appoints Ms Shilpi and Mr Ashish Chandra and OSD in FT&TR Division - Taxindiainternational.com

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INTL - Although outstanding receivables from an AE constitute a separate international transaction amenable to benchmarking, determination of ALP has to depend upon the facts and circumstances of each case: ITAT (See Breaking News)

TP - An APA concluded by CBDT, though not directly applicable to earlier AY, has significant persuasive value where nature of international transactions & FAR profile remain comparable: ITAT (See Breaking News)

INTL - Penalties u/s 271AA & 271G not valid where AO failed to point out any specific missing documents & where TPO already accepted transactions at arm's length after verification: ITAT (See Breaking News)

TP - Huge turnover or profit cannot serve as sole basis for exclusion of comparable if company is otherwise functionally comparable under Rule 10B(2): ITAT (See Breaking News)

TP - Once tested party's margins are found to be at arm's length under TNMM, and adequate working capital adjustment is made, no separate adjustment on account of notional interest on delayed receivables from AEs is warranted: ITAT (See Breaking News)

TP - For benchmarking interest on External Commercial Borrowing obtained from Associated Enterprise, CUP method is most appropriate method, as price of lending transaction can be directly compared with comparable uncontrolled loans: ITAT (See Breaking News)

TP - AMP and R&T expenses do not constitute 'international transactions' u/s 92B in absence of agreement to provide services to AEs: ITAT (See Breaking News)

DTAA - Receipts received by Hong Kong tax-resident assessee for providing managed, systems integration and hi-tech transactional services to Standard Chartered Bank through its Indian group company, not taxable in India as royalty or FTS: ITAT (See Breaking News)

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CBDT appoints Ms Shilpi and Mr Ashish Chandra and OSD in FT&TR Division By TII News Services Jan 29, 2021 , New Delhi
GOVERNMENT OF INDIA MINISTRY OFFINANCE DEPARTMENT OF REVENUE CENTRAL BOARD OF DIRECT TAXES NEW DELHI OFFICE ORDER NO 27/2021, Dated: January 28, 2021 With the approval of the Competent Authority, Ms. Shilpi, IRS (IT:16006), presently posted as DCIT (TPO)-2(3), Delhi is, hereby, posted as DCIT (OSD) (FT&TR-V)(1) in FT&TR Division, CBDT, Department of Revenue with immediate effect and until further orders. 2. During the period of posting of Ms. Shilpi, IRS (IT:16006) as DCIT (OSD) FT&TR-V)(1) in FT&TR Division, CBDT, the salary and other allowances for her shall be drawn and disbursed by Principal CCIT (CCA), Delhi. 3. On request of Shri Ashish Chandra, IRS (14092), DCIT (OSD) (FT&TR-V)(1) in FT&TR division, CBDT, Department of Revenue, he is, hereby, repatriated and posted as DCIT (OSD) in the office of Principal CCIT, Delhi Region, with immediate effect and till his further posting is decided. 4. Hindi version of this office order will follow. [F. No. A22013/1/2016-Ad.VI-(Part-1)] D K Verma Director (Ad.VI)

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