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INTL TAXATION INTL MISC TP FDI LIBRARY VISA BIPA NRI
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TP - Transfer pricing adjustment is unwarranted where tolerance band of the ALP adjustment falls within +/- 5% as per second proviso to Section 92C: ITAT (See 'Breaking News') TP -Transfer pricing adjustment framed on account of notional interest on receivables, is justified, where the assessee-company is found to not have incurred any debt: ITAT (See 'Breaking News') Energy crisis drives fall in tax levels in OECD countries I-T- Where assessee's claims of being a non-resident deserved to be accepted, his salary income from Sudan should be exmepted : ITAT (See 'Breaking News') I-T - Final assessment order passed without mentioning mandatory DIN is invalidated: ITAT (See 'Breaking News') TP - Final assessment order passed without incorporating the DRP's directions not valid: ITAT (See 'Breaking News') TP - Penalty imposed u/s 271(1)(c) rightly quashed where additions/disallowances based on which penalty was imposed, are themselves set aside: ITAT (See 'Breaking News') TP - RPM method is most appropriate for benchmarking of pure trading company involved in distribution activity without adding any value to purchased product: ITAT (See 'Breaking News') I-T - Power of revision u/s 263 is rightly exercised if AO in original assessment proceedings, omits to examine issue of license fee & royalty paid by Assessee to its holding companies during relevant period: ITAT (See 'Breaking News') TP - Turnover is relevant criteria for choosing companies as comparables in determining ALP in Transfer Pricing cases: ITAT (See 'Breaking News') I-T- CUP method can be adopted as most appropriate method in the case of the assessee owing to differences on account of volume, geography, functions performed and risks assumed : ITAT (See 'Breaking News') I-T- It is fit case for remand where re-assessment exercise omits to consider claim of Foreign Tax Credit, raised by the Assessee: HC (See 'Breaking News') TP - Resale Price Method incorrectly applied for benchmarking international transaction involving supply of military equipment: ITAT (See 'Breaking News') TP - If AO passes assessment order without receiving directions of DRP and merely relying on TPO's order giving effect to directions of DRP is bad in law: ITAT (See 'Breaking News') I-T - DRP directions issued without a Document Identification Number is invalid and deemed to have never been issued as per CBDT Circular No. 19 of 2019: ITAT (See 'Breaking News') Unraveling Complexity: MFN Clause and Its Tax Treaty Ramifications (See Guest Column in TIOL) I-T - Unless assessee's return is processed and decision taken by reasoned order, assessee would be justified in approaching for direction for refund: HC (See 'Breaking News') I-T - In absence of statutory provisions, retention of refund in anticipation of conclusion of DRP proceedings, and to give credit to this amount while giving-effect to orders thereafter cannot be accepted: HC (See 'Breaking News') TP - Time barred order passed by TPO merits to be quashed: ITAT (See 'Breaking News') Software rentals constitute Royalty: Pakistan SC's recent judgement (See TII Edit)
 
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