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TP - Whether Profit Split Method (PSM) is 'most appropriate method' when data is not available on CUP method as most appropriate method - NO : ITAT (See 'Breaking News') TP - Whether DRP needs to consider detailed submissions of assessee in respect to computation of average operating margins of 15 furnished comparables, before passing assessment order - YES: ITAT (See 'Breaking News') TP - Whether in absence of segmental details, a company having different variations of business, can still be taken into account for comparability analysis - NO: ITAT (See 'Breaking News') TP - Whether draft assessment order passed without having disposed of assessee's objections to reasons in support of notice of reopening, is an invalid order - YES: HC (See 'Breaking News') Creation of TPRU & Tax Policy Council - Govt favours Generalists at cost of Specialists! (See 'The Cob(Web) Column in TIOL) TP - Whether whenassessee has not deposited outstanding demand, doesRevenue has authority to grant further stay with a direction of deposit of previous dues - YES: ITAT (See 'Breaking News') China spending more than Europe on R & D: OECD (See 'TII Brief') TP - Whether a company inbusiness of merchant banker and investment banker, is functionally not similar to that of function of non-binding advisory services - YES: ITAT (See 'Breaking News') India's credibility deficit in retrospective governance persists (See 'TII Special') TP - Whether in absence of details, start up expenses with regard to computation of PLI of assessee, can be disallowed on adhoc basis instead of giving a reasonable estimation after considering relevant aspects - NO: ITAT (See 'Breaking News') TP - Whether activity of brokerage from securities can be compared with investment and financial advisory services - NO: ITAT (See 'Breaking News') TP - Whether when functions and activities carried out by a company are different from functions and activities of assessee company, risk profiles of two are also different, two can still be considered as comparable company for purpose of ALP determination - NO: ITAT (See 'Breaking News') I-T - Whether amount received on account of service tax as part of price of carriage/shipped service is a trading/business receipt and would be part of aggregate amount for presumptive profit and gain to be determined u/s 44B of Act - YES : ITAT (See 'Breaking News') I-T - Whether it can be said that a circular issued by Board is against provision of law, merely because different high courts have interpreted law differently - NO: ITAT (See 'Breaking News') TP - Whether a company cannot be included in list of comparables, when same is functionally not similar to that of assessee and also when other companies have been rejected on similar grounds - YES: ITAT (See 'Breaking News') TP - Whether depreciation claimed by assessee during earlier year to which assessee was not entitled, can be brought back to tax u/s 28(iv), if value of benefit is arising from business of assessee - NO: ITAT (See 'Breaking News') TP - Whether TPO has no jurisdiction to initiate penalty proceedings u/s 271G - YES: ITAT (See 'Breaking News')
 
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TII BREAKING NEWS
 
TP - Whether Profit Split Method (PSM) is 'most appropriate method' when data is not available on CUP method as most appropriate method
TP - Whether DRP needs to consider detailed submissions of assessee in respect to computation of average operating margins of 15 furnished comparables
TP - Whether draft assessment order passed without having disposed of assessee's objections to reasons in support of notice of reopening, is an invalid order ....
TP - Whether in absence of segmental details, a company having different variations of business, can still be taken into account for comparability analysis ....
< More News >
 
TII EXCLUSIVE Feb 01, 2016
 
6 more to go: the US tax essay…
By Laurence E Lipsher

IT is hard to believe that we are nearly at the end of the first month of the new year. As of the 19th of January, one could file their US tax return - the earliest in memory. Of course, let's be honest about it - as I get older, my memory span shortens ....

 
TII EDIT Jan 27, 2016
 
The Indian Poem
By D P Sengupta

Taxation depends on residency, at least in most of the countries of the world that levy income tax. Barring a few, most of the countries also tax their residents on worldwide basis. Generally speaking, non-residents are taxed not on worldwide basis but on what they earn from the country in ....

 
TII SPECIAL Feb 03, 2016
 
India's credibility deficit in retrospective governance persists
By Naresh Minocha

INDIAN Prime Minister Narendra Modi has repeatedly assured foreign investors that retrospective taxation would not be revived. He has also promised predictable tax regime.

An official release has quoted Mr. Modi as stating "retrospective tax was a thing of the past, and a closed chapter." He articulated his stance on retro tax at India-France ....

 
TII BRIEF
 
New Delhi, Feb 04, 2016
China spending more than Europe on R & D: OECD ...
Paris, Jan 29, 2016
OECD Chief welcomes EC's proposal to curb tax avoidance...
New Delhi, Jan 28, 2016
India-USA DTAA - MAP - 100 TP cases out of 200 resolved: CBDT...
Paris, Jan 28, 2016
31 countries ink tax agreement for country-by-country information...
Paris, Jan 28, 2016
Malaysia signs MCAA for auto exchange of information...
 
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