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NEWS FLASH

I-T- Compulsorily Convertible Debentures & Optionally Convertible Debentures, until conversion, retain essential characteristics of debt instruments akin to NCDs; ergo, qualify as debentures or bonds for tax purposes: ITAT (See Breaking News)

TP - Separate adjustment for receivables results in duplication, if economic effect of extended credit period is already subsumed in working capital adjustment: ITAT (See Breaking News)

I-T -Payments received by assessee will be business profits rather than royalty, where assessee merely organizes publicly available scientific information in a database & provides access to it, without transferring any copyright or proprietary rights to customers: ITAT (See Breaking News)

TP - TPO's approach in insisting upon daily/monthly working capital cycle data of third-party comparable is, unjustified if such data is admittedly not available in public domain: ITAT (See Breaking News)

TP- TNMM operates at net margin level & tolerates transactional differences; hence pricing mechanism or revenue scale alone cannot justify rejection of internal TNMM: ITAT (See Breaking News)

INTL - As is trite law, filing of Form 67 is directory and not mandatory; delay in filing Form 67 should not lead to disallowance of Foreign Tax Credit: ITAT (See Breaking News)

TP - Reference which was made to TPO after date when clause (i) of section 92BA was omitted by Finance Act, 2017, is not sustainable: ITAT (See Breaking News)

I-T - Reimbursement of salary paid to AEs which are merely in nature of reimbursements of seconded employee and does not include any element of income, does not attract TDS: ITAT (See Breaking News)

I-T - Final assessment order passed by AO merits to be quashed if it is not in conformity with DRP directions: ITAT (See Breaking News)

I-T - If allocation/attribution of income to PE is at arm's length, then no further ad-hoc attribution is required: ITAT (See Breaking News)

TP - While principle of res judicata does not apply to tax proceedings, the principle of consistency must be observed, especially where there is no change in facts or legal position: ITAT (See Breaking News)

TP - Provision for bad & doubtful debts is only accounting treatment and have no direct nexus to operating income: ITAT (See Breaking News)

TP - Working capital adjustment can't be denied merely due to absence of detailed working capital cycle data and adjustment should be granted based on average of opening & closing balances: ITAT (See Breaking News)

DTAA - Prior taxability of similar income in earlier years does not bar assessee's lawful claim for relief in current year, more so when there is no change in facts: ITAT (See Breaking News)

Netherlands to grow at 1.3% rate in 2025: OECD (See Brief)

TP - Corporate guarantee given by assessee on behalf of AE in absence of any expenditure being incurred by assessee, would not constitute international transaction within meaning of Sec 92B: ITAT (See Breaking News)

TP - Gross profitability margin may vary significantly over time, and hence, reliance on data of earlier years would not constitute reliable benchmark: ITAT (See Breaking News)

DTAA - Management support services do not make available any technical knowledge or skill to recipient; ergo, consideration therefor is not taxable as FTS under India-Singapore DTAA: ITAT (See Breaking News)

I-T - Amortization of capital subsidy in itself is not allowable as direct deduction u/s 80-IC, rather impact of capital subsidy is reflected in reduced "actual cost" of asset, leading to claim of lower depreciation: ITAT (See Breaking News)

I-T - If repair & maintenance of aircraft equipment provided by foreign assessee to Indian airline operators, did not involve transfer of technology, then receipts from said services are not taxable as FIS: HC (See Breaking News)

TP - If number of transactions are closely linked, then same should be treated as composite transaction and can be aggregated and construed as single transaction for purpose of determining ALP: ITAT (See Breaking News)

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TII BREAKING NEWS

New Delhi, Jul 18, 2025 By TII News Service

I-T- Compulsorily Convertible Debentures & Optionally Convertible Debentures, until conversion, retain essential characteristics of debt instruments akin to NCDs; ergo, qualify as debentures or bonds

Ahmedabad, Jul 18, 2025 By TII News Service

TP - Separate adjustment for receivables results in duplication, if economic effect of extended credit period is already subsumed in working capital adjustment: ITAT

Mumbai, Jul 17, 2025 By TII News Service

I-T -Payments received by assessee will be business profits rather than royalty, where assessee merely organizes publicly available scientific information in a database & provides

Hyderabad, Jul 17, 2025 By TII News Service

TP - TPO's approach in insisting upon daily/monthly working capital cycle data of third-party comparable is, unjustified if such data is admittedly not available in

< More News >

FROM TII ARCHIVE

Jun 29, 2010

Source State Taxation and India - What the future holds?

By A. J. Majumdar

TAXATION of persons owing economic allegiance to a State is the sovereign right of that State exercisable only within its boundary. The operation of the law can also extend to persons, things and acts outside the State in certain circumstances. Government of India Act, 1935, or Article 245 of the Constitution of Independent India

View Previous Column >>

TII EDIT

Jun 20, 2025

The Revenge Tax of Mr Trump

By D P Sengupta

20th January 2025. Immediately after assuming the office of the US presidency, Mr. Donald Trump, issues a flurry of executive orders and executive notes. One such note is captioned the "America First Trade Policy." Outlined therein are a slew of actions to be taken by the Secretary of the

View Previous Column >>

BULLETIN BOARD

New Delhi, Jul 02, 2025
CBDT notifies 376 as cost inflation index...

New Delhi, Jul 01, 2025
larification regarding CBDT's Circular No. 5/2025 dated 28.03.2025 for waiver on levy of i...

New Delhi, Jun 25, 2025
CBDT notifies Protocol amending India-Oman DTAA ...

New Delhi, Jun 25, 2025
Relaxation of time limit for processing of valid returns of income filed electronically pu...

< More News >

TII BRIEF

Paris, Jul 10, 2025
Netherlands to grow at 1.3% rate in 2025: OECD ...

Paris, Jun 27, 2025
OECD to release Tax Inspectors Without Borders' 10-yr Report ...

Paris, Jun 12, 2025
Germany faces skilled labour paucity: OECD ...

Paris, May 26, 2025
G20 merchandise exports logs 2% growth in Q1 ...

Paris, May 16, 2025
OECD unemployment rate remains stable at 4.9% in March ...

More News >>

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