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I-T - Whether amount received by an assessee by way of reimbursement, can be excluded from amit of Section 44BB - NO: HC (See 'Breaking News') TP - Whether CUP method is most appropriate method to determine ALP in cases where there is no variation in hourly billing rate between AE and non-AE for man power supply - YES: ITAT (See 'Breaking News') TP - Whether in case issue regarding TP requires a fresh look by lower authorities, so that revenue stream is correctly bifurcated between AE and non-AE segment, an opportunity to file additional evidence can be denied to assessee - NO: ITAT (See 'Breaking News') TP - Whether it is open to I-T Authorities to replace 'sale consideration'/'projected value' adopted by assessee for selling IPR to its AE, with actual values, where such sale consideration was arrived at after considering independent valuation from two valuers - NO: ITAT (See 'Breaking News') Payments to non-resident - No requirement of PAN of deductee - Procedures simplified (See 'Notification' in Intl Taxation) The Mortar for The BRICS (See 'Edit') TP - Whether additional evidences filed by assessee in respect of segmental data relating to internal comparables, deserves to be admitted, for arriving at segmental P&L A/c in relation to transaction with AE and Non-AE's for revenue of associated cost - YES: ITAT (See 'Breaking News') TP - Whether when assessee did not make entry in P&L A/c in year in which liability actually accrued, assessee's claim has to be denied in such a case - NO: ITAT (See 'Breaking News') I-T - Whether receipts regarding reimbursement of travelling expenses and living allowance paid to expatriates, can be considered as forming part of fees received by assessee, same can be taxed in hands of assessee - NO: ITAT (See 'Breaking News') Review of Foreign Direct Investment (FDI) policy on various sectors (See 'Press Note' in Fdi) CBDT finally notifies GAAR w.e.f April 1, 2017 (See 'Notifications' in Intl Taxation) TP - Whether allowing a credit period on receivable from AE is not an independent international transaction, it is to be considered as a part of main international transaction of providing software development services by assessee to its AEs - YES: ITAT (See 'Breaking News') TP - Whether when no fresh evidence, record or facts are required to be investigated, in that case there is no bar in admitting additional ground for adjudication of issue of functional comparability of a company - YES: ITAT (See 'Breaking News')
 
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TII BREAKING NEWS
 
I-T - Whether amount received by an assessee by way of reimbursement, can be excluded from amit of Section 44BB ....
TP - Whether CUP method is most appropriate method to determine ALP in cases where there is no variation in hourly billing rate between AE ....
TP - Whether in case issue regarding TP requires a fresh look by lower authorities, so that revenue stream is correctly bifurcated between AE and ....
TP - Whether it is open to I-T Authorities to replace 'sale consideration'/'projected value' adopted by assessee for selling IPR to its AE, with actual ....
< More News >
 
TII EXCLUSIVE Jun 15, 2016
 
The end of May tax potpourri
By Laurence E Lipsher

AH, here we are, nearly 5/12 of the year is over; the weather is still tolerable in China's Pearl River Delta for me but it'll soon change as the heat and humidity becomes, well…..unbearable. And yet one learns to put up with it as I have here in Asia for the ....

 
TII EDIT Jun 27, 2016
 
The Mortar for The BRICS
By D P Sengupta

I am just back from one of the many BRICS conferences that are happening all over the world. This one was organized by the BRICS Law Institute in Ekaterinburg, Russia. Originally, there was only BRIC, thanks to the acronym coined in 2001 by Jim O'Neil of Goldman Sachs (Building better ....

 
TII SPECIAL Jun 09, 2016
 
Spurt In Oil Prices
By Prof M R Dua

YOU would surely have noticed, albeit with little surprise, that petrol and diesel prices in Delhi were revised upward last week. In fact, there have been many frequent fluctuations in the costs of petroleum products in the recent months. This has reportedly been due to continual changes in the global ....

 
TII BRIEF
 
New Delhi, Jun 22, 2016
Cabinet okays Protocol amending India-Belgium DTAA...
Paris, Jun 15, 2016
OECD Council okays insertion of BEPS-sponsored inputs in TP Guidelines...
New Delhi, Jun 14, 2016
Impact of amendment in India-Mauritius DTAA - Working Group to submit report in 90 days...
New Delhi, Jun 13, 2016
Impact of amendment in India-Mauritius DTAA - Working Group to submit report in 90 days...
Paris, Jun 08, 2016
Reform of legal labour migration policies of EU needed : Report...
 
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    The Week That Was - Episode 44 (June 24, 2016)