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I-T - Amounts received by assessee for use of transponder of tele-communication service charges are not royalty: ITAT (See Breaking News)

I-T - Gains derived by Singapore-resident seller from sale of shares of Singapore-resident company are taxable only in Singapore, even if shares derive substantial value from Indian assets: ITAT (See Breaking News)

DTAA - Payments received by non-resident assessee for licensing standard software & connected incidental services to Indian customer is not royalty, taxable in India u/s 9(1)(vi) or Article 12 of India-Ireland DTAA: ITAT (See Breaking News)

TP - Working capital adjustments are attempt to arrive at adjusted comparables as basis of determining their profit level indicators or comparable uncontrolled prices: ITAT (See Breaking News)

TP - If loan given to AE was non-performing asset, no adjustment can be made for notional interest if there is no possibility of recovering either interest or principal: ITAT (See Breaking News)

I-T - Once certain transaction is accepted at arm's length by TPO in earlier & later AYs, under an agreement unchanged for more than a decade, then absence of TPO reference in current AY cannot prejudice assessee: ITAT (See Breaking News)

I-T -Payments received for distribution, sale, or exhibition of cinematographic films fall within exclusion in Explanation 2(v) to section 9(1)(vi); is excluded from 'royalty' under Article 12 of India–USA DTAA: ITAT (See Breaking News)

Shadow of Litigation on GAAR thus far (See 'TII Edit')

Ageing population to strain European pension systems: OECD (See Brief)

DTAA - Delivery Order Charges are directly connected to transportation of goods; fall within scope of Article 8 of India-Turkey DTAA - such charges not taxable in India, as are collected after transportation at point when goods handed over to consignee: ITAT (See Breaking News)

African GDP may double if USD 155 bn pumped into infra sector: OECD (See Brief)

INTL - CSR contributions, though not allowable as business expenditure u/s 37(1), qualify for deduction u/s 80G if the prescribed conditions are fulfilled: ITAT (See Breaking News)

TP - Ttransaction between assessee and AE is in foreign currency with regard to receivables, then transaction would have to be looked upon by applying commercial principles with regard to international transactions - YES: ITAT (See Breaking News)

TP - If CCDs issued are in nature of debt, then interest paid on same should be benchmarked as per applicable transfer pricing provision after applying most appropriate method considering availability of data: ITAT (See Breaking News)

Illicit trade in tobacco results in revenue loss of over USD 47 billion: WHO (See Brief)

TP - Capital financing between two AE should be benchmarked as loan transaction for noticeably brief period between two related parties where there is minimum risk: ITAT (See Breaking News)

TP - Each international transaction must be separately evaluated u/s 92C; acceptance of benchmarking for basic market-research services does not automatically cover infrastructure service fees & reimbursements: ITAT (See Breaking News)

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Exchange facility to foreign citizens By TII Jan 13, 2017 , New Delhi
A P (DIR Series) CIRCULAR NO 24/RBI., Dated: January 3, 2017 Exchange facility to foreign citizens Attention of Authorized Persons is invited to the A.P. (DIR Series) Circular No. 20 dated November 25, 2016 permitting foreign citizens to exchange foreign exchange for Indian currency notes up to a limit of Rs 5000/- per week till December 15, 2016 and extended up to December 31, 2016 vide A.P. (DIR Series) Circular No. 22 dated December 16, 2016. 2. On a review it has been decided that the instructions contained in the A.P. (DIR Series) Circular No. 20 dated November 25, 2016 shall continue to be in force till January 31, 2017. 3. Authorised Persons may follow the above instructions and bring the contents of this circular to the notice of their constituents. 4. The directions contained in this circular have been issued under Section 10(4) and Section 11(1) of the Foreign Exchange Management Act, 1999 (42 of 1999) and are without prejudice to permissions/approvals, if any, required under any other law. RBI/2016-17/208 (Shekhar Bhatnagar) Chief General Manager-In-Charge

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