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TP - Whether for computing net margin of assessee for purposes of transfer pricing, only cost related to transaction with Associated Enterprises has to be considered and accordingly, segmental financials is to be considered - Whether when bad debts etc. are not related to AE transactions they can be considered as part of operating cost for determining ALP of transactions with AE (See 'TII Breaking News')

I-T - Whether evidences produced and issues decided during assessment proceedings are not final or binding in penalty proceedings - Whether confirmation of any disallowance or addition during assessment or appellate proceedings cannot be basis for invoking provisions of section 271(1)(c) - Whether there is a difference between a false claim and a genuine claim - Whether non-deduction of tax as per provisions of chapter XVII of Act, should not result in imposition of penalty under section 271(1)(c) (See 'TII Breaking News')

I-T - Whether to decide whether a PE stood constituted, one has to undertake a factual and functional analysis of activities undertaken by establishment - Whether such determination is primarily a factual issue - Whether word ‘permanent’ in term ‘permanent establishment’ does not in any manner signify or denote a permanent character, or that right to use place should be perpetual - Whether how fixed place or right to use same is secured is of little consequence - Whether though bagging a high value contract does not by itself generate income, it definitely requires undertaking of concerted work, which is only toward carrying on its business (See 'TII Breaking News')

I-T - Whether commission payments to foreign agents on export sales, made prior to October 2009, are not liable for deduction of tax at source under section 195 - Whether services provided by commission agent for procuring orders can be covered under section 9(1)(vii) as managerial services - Whether Duty Draw Back and other export incentives, not being income derived from industrial undertaking, are not eligible for deduction under section 80IB (See 'TII Breaking News')

TP - Whether while applying CUP Method with respect to purchase of palm oil from Malaysia, quote given by a Publication, an independent organisation, cannot be ignored merely because it is located outside Malaysia - Whether when CIT(A) and Tribunal have accepted such a price quote, no substantial question of law arises for High Court (See 'TII Breaking News')

Foreign Direct Investment in Pharmaceuticals sector - clarification (See 'RBI Circulars' in FDI)

I-T - Whether expenses incurred by head office, located overseas, for Indian project, including salary of expatriate staff, are allowable to assessee - Whether argument that assessee has not proved nexus of expenditure claimed to project in India, can be entertained at stage of proceedings before Tribunal, when neither AO nor CIT(A) had not stated that expenditure claimed had no nexus with Project in India (See 'Breaking News')

NRI - Whether a person whose passport has been illegally impounded and he is forced to stay in excess of 182 days in India, becomes a resident as per section 6(1)(c) - Whether when because of untenable actions of executive, a tax payer is exposed to peril of loosing his valuable right of retaining his NRI status, a literal meaning of provision relating to residence will lead to a manifest absurdity- Whether untenable impounding of passport and restriction on freedom of movement to travel abroad and adverse tax consequences cannot be intention of legislature (See 'Breaking News')

I-T- Whether Section 172 incorporates a prohibition for invoking reassessment proceedings under Section 147/148 - Whether a company incorporated in Dubai and carrying on shipping business in India is entitled to benefit under Article 8 of DTAA between India and UAE (See 'TII Breaking News')

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')

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TII BREAKING NEWS

Hyderabad, Apr 23, 2014 By TII News Service

TP - Whether for computing net margin of assessee for purposes of transfer pricing, only cost related to transaction with Associated Enterprises has to be ....

Mumbai, Apr 23, 2014 By TII News Service

I-T - Whether evidences produced and issues decided during assessment proceedings are not final or binding in penalty proceedings ....

Ahmedabad, Apr 22, 2014 By TII News Service

TP - Whether while applying CUP Method with respect to purchase of palm oil from Malaysia, quote given by a Publication ....

Mumbai, Apr 22, 2014 By TII News Service

I-T - Whether to decide whether a PE stood constituted, one has to undertake a factual and functional analysis of activities undertaken by establishment - ....

< 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 ....

View Previous Column >>

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, ....

View Previous Column >>

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 ....

View Previous Column >>

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 ...

More News >>

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