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TP - Whether in absence of any agreement for payment of AMP expenses to AE's, can it be held that there was an international transaction, only on basis that AMP expenditure incurred by assessee would have benefitted AE's, who owned brands used by assessee - NO: ITAT (See 'Breaking News') TP - Whether in case there is no investment made by assessee during year, in such a case there cannot be any expenditure on legal and professional fees as well as common expenditure regarding such investment - YES: ITAT (See 'Breaking News') TP - Whether even after Considering facts that there is no agreement between assessee and AEs for sharing AMP expenses, payment made by assessee under head AMP to domestic parties, failure of TPO prove that expenses were not for business carried out by assessee in India, can it still be held that transaction involved is an an international transaction - NO: ITAT (See 'Breaking News') TP - Whether CUP serves as MAM for determining ALP of an international transaction, where some direct comparable uncontrolled instance of purchase or sale of similar goods or services are available - YES: ITAT (See 'Breaking News') TP - Whether a transaction of royalty income of an assessee with its AE can be considered as an operating income of assessee while working out its PLI, where such transaction of royalty is a mere pass through cost, not resulting into any profit and loss in hands of assessee, as per master license & franchise agreement - NO: ITAT (See 'Breaking News') Three jurisdictions this time around (See 'TII Exclusive') Govt. Approves 7 Proposals of FDI Amounting to Rs. 517.57 crore Approximately (See 'FDI Approved') TP - Whether an entity engaged in infrastructure in area of special economic zone, urban infrastructure, agri-infrastructure & offshore terminal, can be compared to an entity engaged into application of TP - Whether merely because a question of law decided by High Court has been challenged by Revenue before Supreme Court, its ratio cannot be applied - NO: HC (See 'Breaking News') I-T - Whether if services carried on by assessee are in connection with prospecting for mineral oils, applying provisions of various services in connection with prospecting for, or extraction or production of mineral oils, is taxable on presumptive basis u/s 44BB - YES: ITAT (See 'Breaking News') I-T - Whether in case it has been made clear by statute itself that income from services rendered in connection with providing drilling rigs/drilling services to contractor in India are in nature of services and facilities in connection with, or supplying plant and machinery on hire which are used in prospecting for extraction or production of mineral oil, provisions of section 44BB would apply in that case - YES: ITAT (See 'Breaking News') TP - Whether in case there was no separate expenditure shown under head ‘salary/ remuneration', subhead ‘cost of service', primarily refers to employees cost, which may also cover contribution to PF, ESI, gratuity and ex gratia payment - YES: ITAT (See 'Breaking News')
 
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TII BREAKING NEWS
 
TP - Whether in absence of any agreement for payment of AMP expenses to AE's, can it be held that there was an international transaction, ....
TP - Whether in case there is no investment made by assessee during year, in such a case there cannot be any expenditure on legal ....
TP - Whether even after Considering facts that there is no agreement between assessee and AEs for sharing AMP expenses, payment made by assessee under ....
TP - Whether CUP serves as MAM for determining ALP of an international transaction, where some direct comparable uncontrolled instance of purchase
< More News >
 
TII EXCLUSIVE May 02, 2016
 
Three jurisdictions this time around
By Laurence E Lipsher

WHAT better a circumstance in which to write: I just got up from a pleasant Sunday afternoon nap, took a look outside and promptly forgot about thoughts of taking a walk across our neighboring university campus while listening to my music with my wireless earphones connected to the 37 gigs of 'my music' on ....

 
TII EDIT Apr 21, 2016
 
Panama follows Cyprus?
By D P Sengupta

LET me add my two bits to the reams that have already been written about Panama Papers. The outrage that followed the disclosure of all the colourful schemes dreamt up by lawyers and facilitators of offshore tax evasion has already subsided and in a few more days will fade from public memory. Nevertheless, the ....

 
TII SPECIAL Mar 29, 2016
 
View China's slowdown forecasts along with its tax & allied reforms
By Naresh Minocha

CHINA's growth slow-down has transformed it into an intense subject of crystal-gazing. Reputed global entities have lately released interesting studies measuring the impact of slow-down on different countries, industries and commodities market under different scenarios.

Some studies have drawn policy lessons for other countries as well. They have also figured out opportunities ....

 
TII BRIEF
 
Paris, Apr 27, 2016
If UK leaves EU it would be paying heavy 'Brexit tax' for many years: OECD Study...
Paris, Apr 21, 2016
OECD, African Panel resolve to deal with illicit financial flows ...
Paris, Apr 20, 2016
New Tax Forum to focus on developing toolkits for developing countries ...
Paris, Apr 14, 2016
OECD countries double spending on refugees; Development Aid up in 2015 ...
New Delhi, Apr 13, 2016
Foreign Cos can now set up BO or LO without registering in India ...
 
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    Legal Wrangle - Episode 39 (International & Direct Tax)