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DTAA - Deploying specialized software, technical resources, or copyrighted items as medium to deliver services does not amount to granting right to use copyright or intellectual property per India-USA DTAA; consideration payable therefor is not Royalty: ITAT (See Breaking News)

I-T - Assessee is entitled to concessional rate u/s 115BAA despite delayed filing of Form 10-IC, when option had already been exercised in return of income: ITAT (See Breaking News)

INTL - Once Revenue accepts that no income is taxable in India for relevant AY, the corresponding TDS deducted at source cannot be withheld & assessee is entitled to claim credit per Rule 37BA of I-T Rules: ITAT (See Breaking News)

INTL - Digital transmission & uploading of orders on ITBA portal is valid receipt by AO, effectively starting limitation clock from that date rather than from any subsequent physical handling or note-sheet entry: ITAT (See Breaking News)

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I-T - Final assessment order passed u/s 143(3), 144C(13) and 144B can be quashed as time-barred if it is passed beyond outer limitation prescribed u/s 153 r/w/s 144C: ITAT (See Breaking News)

I-T - Subsidiary with own manufacturing unit, independent customer base can't not be treated as economically dependent on its foreign parent, and does not constitute a Dependent Agency PE: ITAT (See Breaking News)

TP - Fully & compulsorily convertible debentures retain their character as debt until actually converted into shares & regulatory frameworks or accounting standards operating in different fields cannot be imported to alter this position for transfer-pricing purposes: ITAT (See Breaking News)

TP - Revenue must first establish existence of international transaction regarding AMP expenses de hors Bright Line Test, which has no statutory mandate: ITAT (See Breaking News)

I-T - Requirement of furnishing Form 67 is directory and procedural & cannot override substantive entitlement to credit for foreign taxes paid u/s 90 or 90A: ITAT (See Breaking News)

TP - For cross-border transactions involving foreign currency receivables, the appropriate interest rate to adopt is LIBOR rate rather than domestic rates: ITAT (See Breaking News)

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Calling for applications for posting at Under Secretary Level in Foreign Tax & Tax Research Division of CBDT By TII News Service Feb 07, 2018 , New Delhi
F.No.500/52/2010-FTD.I/291-292 GOVERNMENT OF INDIA MINISTRY OF FINANCE DEPARTMENT OF REVENUE CENTRAL BOARD OF DIRECT TAXES (FOREIGN TAX & TAX RESEARCH-I DIVISION) Dated: February 7, 2018 To All Principal Chief Commissioner of Income Tax (CCA) Subject: Calling for applications for posting at Under Secretary Level in Foreign Tax & Tax Research Division of CBDT- reg. This is to inform you that one post at the level of Under Secretary in FT&TR Division, CBDT has fallen vacant, which is to be filled up on urgent basis from the IRS Cadre. 2. In this regard, reference may be made to this division's OM of even no. dated 31.10.2017 (copy enclosed). It is to be informed that the last date for submission of application has been extended to 28.02.2018 with the same terms and conditions. Applicants may accordingly apply. 3. Applicant officers may send an advance copy of their application along with the brief resume through e-mail to pragya.saksena@nic.in (Deepak Kapoor) Under Secretary (FT&TR-1(1)]

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