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NEWS FLASH
 
Govt notifies Consolidated FDI Policy effective from April 17 (See 'FDI Circulars') Interesting - Judicial Reforms find space in Manifestos! (See 'THE COB (WEB)' in Taxindiaonline.com) I-T - Whether nature of service provided by a non-resident company transmitting bulk sms requires any technical knowledge - Whether in such case what was rendered was just transmission of data which requires no technical skill - Whether these services do not involve human intervention and hence cannot be regarded as fee for technical services (See 'TII Breaking News') TP - Whether canvassing of orders abroad amounts to managerial services - Whether same can be said to be for any consultation - Whether export commission paid to non-resident agent for procuring and canvassing export orders abroad amounts to rendering of technical services (See 'TII Breaking News') FEMA - Whether although cause of action for filing an appeal before High Court has arisen under FERA, limitation period for such an appeal would be governed by section 35 of FEMA - Whether when Enforcement Directorate has merely stated that there was inaction and negligence on part of various officers, whether it amounts to ‘sufficient cause’ for excusing a delay of 775 days - Whether delay can be condoned as a matter of routine when vested right accrues in favour of opposite party (See 'TII Breaking News') TP - Whether when if deduction is not claimed in original return , Assessing Officer cannot entertain claim for deduction otherwise than in a revised return - Whether such restriction applies to appellate authorities - Whether under-utilization of production capacity in initial years is a vital factor which can not be ignored while determining ALP (See 'TII News Service') IMF acknowledges Hong Kong's initiative on long-term fiscal policy (See 'TII Brief') TP: No Cost - No Guarantee? (See 'TII Edit') TP - Whether once assessee has given a methodology for working of ALP on selection of a particular method supported by appropriate comparables, working can be dislodged by TPO only on basis of cogent reasons and objective findings - Whether assessee's selection of CPM for manufacturing segment and RPM for trading segment can be discarded by TPO on basis of theoretical assertions and generalized observations - Whether while applying TNMM, TPO can reject segmental data and instead adopt entity level calculations (See 'TII Breaking News') IMF focuses on expenditure reforms for effective fiscal consolidation (See 'TII Brief') I-T - Whether tax is to be deducted at source in respect of ocean freight charges, air freight charges and inland charges - Whether payments made to shipping agents of non residents is nothing but reimbursement of charges- Whether for payments below Rs 20,000, there is any TDS obligation (See 'TII Breaking News') I-T - Whether ITAT has jurisdiction to grant stay exceeding a period of 365 days - Whether even if there is a prima-facie case, stay should not be granted exceeding 365 days. (See 'TII Breaking News') TP - Whether when Indian subsidiary has earned profit whereas its AE has continuously sustained losses, with no element of profit in hands of AE, there is any case of shifting of profits to AE - Whether when AE is resident in USA which has a higher tax rate than in India, there is any commercial prudence to shift profit out of India - Whether TP adjustment can be done without evaluating FAR properly - Whether without providing objective justifications as to why and how PSM method applied by assessee in peculiarities of business was not an appropriate method, Revenue could adopt TNMM to make an adjustment (See 'TII Breaking News') I-T - Whether mobilization fee, reimbursement of communication charges and repair should be taken in gross receipts for calculation of taxable profits under section 44BB - Whether Section 44BB being a complete code in itself, provides by a legal fiction profits and gains of non resident assessee to be taken for purpose of said section - Whether when it is not in dispute that amount has been received by assessee company, same has to be included for purpose of taxation - Whether service tax being a statutory liability cannot form part of gross receipts for purpose of deemed profit under section 44BB. (See 'TII Breaking News') EPFO prescribes Form for collecting 'Certification of Coverage' under SSA (See 'EPFO' in VISA) Nobel laureates recognise six recipients of Oslo Business for Peace Award 2014 (See 'TII Brief')
 
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TII BREAKING NEWS
 
I-T - Whether nature of service provided by a non-resident company transmitting bulk sms requires any technical knowledge - Whether in such case what was ....
TP - Whether canvassing of orders abroad amounts to managerial services - Whether same can be said to be for any consultation - Whether export ....
TP - Whether when if deduction is not claimed in original return , Assessing Officer cannot entertain claim for deduction otherwise than in a revised ....
FEMA - Whether although cause of action for filing an appeal before High Court has arisen under FERA, limitation period for such an appeal would ....
< More News >
 
TII EXCLUSIVE Apr 04, 2014
 
The Coming of a Tourist Tax
By Laurence E Lipsher

IT is budget time in all the former colonies of the Empire where thankfully, the sun has set. Only in India there are 'interim' budgets because no one expects the same group of leaders to be in office after the election results come in May. But in Hong Kong, where current leadership will ....

 
TII EDIT Apr 16, 2014
 
TP: No Cost - No Guarantee?
By D P Sengupta

MULTINATIONALS, by definition, operate in different jurisdictions and much of the time through establishing subsidiaries in such jurisdictions. Generally speaking, the parent company of a multinational group will enjoy a better credit rating than most of its subsidiaries, ....

 
TII SPECIAL Apr 04, 2014
 
Tax Planning and Tax Avoidance - The Debate continues
By A J Majumdar

THE controversies surrounding the various tax-avoidance schemes that exploded in the public domain in the last couple of years in the UK and elsewhere reignites the seemingly eternal debate relating to the difference between tax planning and tax avoidance. In this context, it may be worthwhile ....

 
TII BRIEF
 
HongKong, Apr 17, 2014
IMF acknowledges Hong Kong's initiative on long-term fiscal policy ...
Washington, Apr 16, 2014
IMF focuses on expenditure reforms for effective fiscal consolidation...
Oslo, Apr 15, 2014
Nobel laureates recognise six recipients of Oslo Business for Peace Award 2014...
Geneva, Apr 15, 2014
Japan, US, EU concern over Brazil's indirect tax sops to domestic industries...
Manila, Apr 14, 2014
New Zealand's tax revenue as GDP% highest; India's lowest: ADB ...
 
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