CBDT appoints Ms Shilpi and Mr Ashish Chandra and OSD in FT&TR Division

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INTL - Revisionary order passed u/s 263 is invalid, where assessee is not given opportunity to contest the allegations levelled by the CIT: HC (See 'Breaking News')

INTL - Buyback transactions would not be treated as transfer for capital gains purposes; power of revision is unwarrantedly exercised where it is based on a hypothetical assumption of facts: ITAT (See 'Breaking News')

TP - Resale Price Method for benchamarking purposes is appropriate for assessee-company whose activities are limited to purchasing & reselling products without adding any value & which is consistent with those of a routine distributor: HC (See 'Breaking News')

I-T - Payments made overseas for general support services, for which no technology was made available, cannot be taxed as 'FTS': ITAT (See 'Breaking News')

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INTL - Re-assessment proceedings invalidated where based on erroneous information & where commenced in a mechanical manner & without due application of mind: ITAT (See 'Breaking News')

TP - AO could not have assumed jurisdiction u/s 147 based on audit objections after expiry of four years from relevant A.Y: HC (See 'Breaking News')

INTL - Additions framed u/s 69 are invalid where assessee substantiates nature & source of investment & thus discharges onus of proof: ITAT (See 'Breaking News')

DTAA - Comparable company merits being excluded where it operates with extraordinary margins & diverse business interests, including intangibles in contrast to assessee-company: ITAT (See 'Breaking News')

TP - As is trite law, transfer pricing adjustment has to be done only in respect of international transactions with associated enterprises & not at entity level: ITAT (See 'Breaking News')

DTAA - Payments made by Google India Pvt Ltd. to Google Ireland Limited (GIL) for the Adwords program are not in the nature of royalty or FTS & therefore, cannot be taxed in the hands of assessee: ITAT (See 'Breaking News')

TP - No separate ALP adjustment is required for payment of royalty if TNMM approach has been adopted at entity level: 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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