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DTAA - Maintenance support services, education & training services, being intrinsically linked to software sold by assessee, the income therefrom cannot be treated as Fees for technical support: ITAT (See Breaking News) TP - If cost allocation Key on 'headcount basis' was duly examined and accepted by TPO to be at ALP in transfer pricing proceedings u/s 92CA(3), same cannot be subjected to retest by AO: ITAT (See Breaking News) I-T - Condonation of delay should not be used as anticipated benefit for government departments and unless department has reasonable and acceptable genuine reason for delay with bona fide efforts: ITAT (See Breaking News) I-T - Merely having Indian address is not sufficient to demonstrate business connection through which activities have been carried on in India and which has led to earning of income: ITAT (See Breaking News) TP - CUP method can be applied in respect of such transactions only, where products of similar nature have been sold to unrelated parties, within same month & same country: ITAT (See Breaking News) TP - If NIC Codes, functional filter, and profit margin of two companies are different, then they cannot be taken as comparables for purpose of calculating ALP: ITAT (See Breaking News) I-T - Receipts earned by way of subscription towards provision of software-based information security solutions are business profits, not chargeable to tax in India in absence of PE: ITAT (See Breaking News) TP - Captive service provider rendering services on cost-plus basis to its AE, can be compared to multi dimensional entity having huge brand value: ITAT (See Breaking News) TP - Existence of 'arrangement' is condition precedent to trigger Sec 80IA(10) and in its absence, business transacted between eligible units and its AE are not covered within Specified Domestic Transactions u/s 92BA: ITAT (See Breaking News) TP - Mere assertion of adoption of 'other method' under Rule 10AB is not sufficient for valid transfer pricing adjustment: ITAT (See Breaking News) I-T-Re-assessment not tenable where based on incomplete assessment of submitted documents & where no evidence is submitted to prove inadequate creditworthiness or that transaction was not genuine: ITAT (See Breaking News) TP - Deduction is available for reversal of provision of doubtful debts which was created and offered to tax during earlier assessment years: ITAT (See Breaking News) DTAA - Health & Education Cess cannot be levied on tax determined under DTAA, as tax rate under DTAA is fixed & cannot be further increased by Cess or surcharge: ITAT (See Breaking News) I-T- If provision for doubtful debts was reduced by corresponding amount from gross trade receivables on asset side, same will amount to write off which is not hit by clause (i) of the Explanation (I) to Sec 115JB: ITAT (See Breaking News) TP - If loss of electricity Board is affected by extraordinary circumstances which are not in existence in close distribution environment, then standard loss prevailing in industry shall be taken as benchmark: ITAT (See Breaking News) I-T - DDT is paid by domestic company resident in India, and it is tax on its income and not tax paid on behalf of shareholder, hence domestic company u/s 115O does not enter domain of DTAA at all: ITAT (See Breaking News) International tax beyond Donald Trump (See TII Edit)
 
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Applications invited for posts of Director / DS in FT&TR in CBDT
By TII News Service
Aug 29, 2019 , New Delhi

    

[F.NO. 500/12/2019-SO/FT&TR-II(2)/213]
GOVERNMENT OF INDIA
MINISTRY OF FINANCE
DEPARTMENT OF REVENUE
FOREIGN TAX AND TAX RESEARCH-II

Dated: August 29, 2019

All the Principal Chief Commissioner of Income-tax (CCA)

Subject: Filling up vacancies at the level of Director/Deputy Secretary in Foreign Tax & Tax Research (FT&TR) Division, CBDT, Department of Revenue-reg.

Vacancies at the level of Director/Deputy Secretary are expected to arise in FT&TR Division, CBDT which are to be filled up from the IRS cadre.

2. In view of the above, I am directed to request that applications (along with brief resume as per enclosed proforma) for the post of Director /Deputy Secretary from willing IRS officers (2004 batch onwards) of the rank of Joint/Additional Commissioner of Income-tax having experience in the field of International Taxation, transfer pricing, APA and/or working in CBDT, posted in your region may be forwarded to Joint Secretary (FT&TR-II) CBDT, Room No. 804, C-Wing, Hudco Vishala Building, Bhikaji Cama Place, New Delhi -110066 by 16th September,2019.

3. Applicant officers may send advance copy of their application along with brief resume on the e-mail: usftd2ii-dor@gov.in.

End: As above:

(Kuldeep Sharma)
Under Secretary (FT&TR-II)(2)

PROFORMA

Name  
Civil list code  
Date of Birth  
Present Posting/ Contact details
 
Educational Qualifications  
Posting profile  
Work experience in International Taxation, Transfer pricing, APA and /or working in CBDT in not more than 500 words.
 
 
 
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