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Trump's Tariff Tantrums (See 'TII Edit')

I-T - If assessee's employees have never visited India and direct sales to Indian customers were made from Singapore through shipment, it cannot be said that assessee has fixed place PE in India: ITAT (See Breaking News)

TP - Functional dissimilarity and absence of segmental information, calls for exclusion of comparable: ITAT (See Breaking News)

I-T - Foreign Tax Credit cannot be denied merely because there is delay in filing Form-67: ITAT (See Breaking News)

I-T - If Contracting States to tax treaty intend to extend treaty protection to domestic company paying dividend distribution tax u/s 115-O, then only domestic company can claim treaty benefit, if any: ITAT (See Breaking News)

TP - If assessee is debt free company and has recovered remittances within agreed terms, there is no red flag of excessive delay in remittance which gives impression that AE is enjoying credit facility beyond reasonable period: ITAT (See Breaking News)

TP - TPO could not have determined Nil ALP for intra group services under CUP method, without bringing on record any comparable uncontrolled transaction: ITAT (See Breaking News)

INTL - Merely receiving salary in India does not render it taxable if services are rendered abroad; taxation depends on place of employment, not mode of salary payment: ITAT (See Breaking News)

I-T - Hypothetical entries in balance sheet and Profit and Loss can't be considered as resulting in real income/expense of assessee: ITAT (See Breaking News)

TP - If assessee purchases goods from its AE and sell same to customers, without any value addition, such transaction needs to be benchmarked using RPM method: ITAT (See Breaking News)

I-T - Amount which is not actually paid by Indian Branch to France HO, can't be treated as FTS in hands of HO under Article-13 of India France DTAA, and hence, can't be taxed in hands of assessee: ITAT (See Breaking News)

TP - Entity which undertakes R&D activities and own intellectual property in form of technology and brand, cannot be compared with software developer: ITAT (See Breaking News)

DTAA - Capital loss incurred under I-T Act r/w Art 13(5) of India-Ireland DTAA can't be set off against short term capital gain derived from sale of rights of entitlement: ITAT (See Breaking News)

TP - AO must provide opportunity of hearing to assessee before transfering his case to TPO, if there is potential of income arising on determination of ALP of international transaction/ specified domestic transaction: HC (See Breaking News)

TP - Comparable company be dropped, where a prior order recalling the inclusion of this company is final and binding: ITAT (See Breaking News)

TP - If ITAT has rightly decided ground pertaining to upward adjustment of international transaction of payment of guarantee fees to AE in favour of Assessee, no writ interference is warranted: HC (See Breaking News)

I-T- Re-assessment proceedings are invalid where reasons recorded by AO are issued after issuing re-assessment notice: ITAT (See Breaking News)

I-T - Role of remitter banker is simply to follow extant procedure and to deduct Tax at source as prescribed under statute: ITAT (See Breaking News)

I-T - If payroll of assessee is in India during assignment period but entire salary reported in Form No.16 is cross charged to Singapore entity, then AO must examine no.of days assessee had worked in India before deciding its taxability: ITAT (See Breaking News)

I-T - If assessee is not having any PE in India and is covered by India US DTAA and MOA, nature of services rendered by assessee on account of which received remunerations can't be described as FIS: ITAT (See Breaking News)

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