Format of reporting under Chapter-IX 'Exchange of Information under Tax Treaties' of Central Action Plan 2016-17

INTL TAXATION INTL MISC TP FDI LIBRARY VISA BIPA NRI

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TP - High cost for services rendered for implementing a software does raise doubts, but mere suspicion is no basis for holding that no services were rendered by AE for said purpose: ITAT (See 'Breaking News')

TP - Companies which are distinct from assessee on account of high turnover, functional dis-similarity & difference in working capital merit being excluded as comparables for benchmarking purposes: ITAT (See 'Breaking News')

INTL -Income of a non-resident assessee cannot be taxed in India where such person is employed abroad during relevant period: ITAT (See 'Breaking News')

DTAA - Fee received for providing technical non-invasive inspection & integrity assessment services for offshore pipelines, cannot be taxed as Fees for Technical Services, considering that Make Available requirement is not satisfied in this case: ITAT (See 'Breaking News')

I-T - Receipts from supply of software products cannot be taxed as royalty or FIS, in absence of transfer of any technical know-how with those products: ITAT (See 'Breaking News')

I-T - It is wholly inequitable for Department to give short credit to tax duly deducted and deposited based on claim that may be made in return of income: HC (See 'Breaking News')

I-T - Bandwidth charges remitted to telecom service providers cannot be treated as royalty either under treaty provisions or u/s 9(1)(vi) of Income tax Act, and hence does not attract TDS: ITAT (See 'Breaking News')

DTAA - Notion that enduring benefit gained by client through repairs & maintenance is akin to make available, is incorrect: ITAT (See 'Breaking News')

DTAA - Providing customer-based information & guidance does not entail problem solving skills or operations or knowledge which allows recipient to perform services independently in future; consideration therefor not treatable as FTS: ITAT (See 'Breaking News')

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')

I-T - If purported reasons that prompted AO to reassess and disallow DAP expenditure incurred on production, only demonstrate change of opinion on part of AO, then same can't form basis of reopening: HC (See 'Breaking News')

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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Format of reporting under Chapter-IX 'Exchange of Information under Tax Treaties' of Central Action Plan 2016-17 By Aug 26, 2016 , New Delhi

INTL TAXATION	INTL MISC	TP	FDI	LIBRARY	VISA	BIPA	NRI	TII
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