Tuesday , May 21, 2019 |   16:45:36 IST
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NEWS FLASH
 
TP - Giant corporation having huge turnover & substantial functional dissimilarity, is unfit for comparison against low end ITES segment: HC (See 'Breaking News') TP - No ALP merits determination, once matter remanded to TPO stands resolved on account of settlement reached under MAP between Assessee and I-T Department: HC (See 'Breaking News') TP - Taxpayer is not precluded from furnishing segmental profitability of AE segment during TP proceedings, simply because he had applied margins at entity level in TP study report: ITAT (See 'Breaking News') TP - For determining ALP in context of Intra group services, taxpayer is not required to prove that quantum of services rendered by AE was higher than unrelated party: ITAT (See 'Breaking News') TP - Once distributor is sufficiently compensated by overseas AE without providing return on marketing intangibles, then no further adjustment on account of AMP expense is warranted: ITAT (See 'Breaking News') DTAA - Income earned by overseas entity from Indian Customers with respect to subscription fees for Chemical Abstracts Services, is not taxable as royalty: ITAT (See 'Breaking News') CBDT issues clarification regarding definition of 'Fund Manager' under Section 9A(4)(b) (See 'Circular' in 'Intl Taxation') I-T - Issue of corporate guarantee by Indian taxpayer entity in favour of its overseas AE is 'international transaction' covered by provisions of Section 92B: ITAT (See 'Breaking News') DTAA - If 'right to use copyright' in software was never transferred by foreign company in favor of Indian customers, then sale proceeds cannot be characterized as 'Royalty': ITAT (See 'Breaking News') TP - Mere arrangement for use of AEs brand name is no basis to infer that parties were acting together to incur higher AMP expense for rendering brand building services: ITAT (See 'Breaking News') TP - Failure to upload electronically Form No 3CEB corroborated with bona fide explanation for such error will not attract penal provisions of Section 271BA: ITAT (See 'Breaking News') I-T - Commission paid to agents abroad for rendering services overseas is not income deemed to accrue or arise in India & hence is not taxable in India: ITAT (See 'Breaking News') TP - Onus on Indian taxpayer entity is limited to prove 'availing of services' & not 'accrual of benefit' w.r.t payments made to their overseas AEs: ITAT (See 'Breaking News') TP - CUP method is not apt for benchmarking export of finished goods to AEs if substantial differences persist on account of functions, geography, volume & risk: ITAT (See 'Breaking News') TP - Once there is transaction between two AEs, it ceases to be 'uncontrolled transaction' and, thereby, goes out of reckoning under Rule 10B(1)(e)(ii): HC (See 'Breaking News') TP - It is not expected from Writ Courts to undertake exercise of comparison which is essentially fact finding exercise: HC (See 'Breaking News') DTAA - Payments made by Indian end-users to foreign licensor of copyright, seeking permission for using software, amounts to royalty and hence attracts TDS: HC (See 'Breaking News') GST - Real Estate - FAQs are welcome but more needs to be done! (See 'The Cob(Web)' in TIOL) TP - Inclusion of FOB value of AE's contract in operating cost in order to determine its margin, is not permitted under TNMM as per Rule 10B(1)(e): HC (See 'Breaking News')
 
 
 
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TII BREAKING NEWS
 
TP - No ALP merits determination, once matter remanded to TPO stands resolved on account of settlement reached under MAP between Assessee and I-T Department:
TP - Taxpayer is not precluded from furnishing segmental profitability of AE segment during TP proceedings, simply because he had applied margins at entity level
TP - For determining ALP in context of Intra group services, taxpayer is not required to prove that quantum of services rendered by AE was
TP - Giant corporation having huge turnover & substantial functional dissimilarity, is unfit for comparison against low end ITES segment: HC
< More News >
 
TII SPECIAL Apr 17, 2019
 
Multilateral Institutions Target Corruption in Fiscal Space
By Naresh Minocha

WHEN International Monetary Fund (IMF) splashes 'Curbing Corruption' on the cover page of its Fiscal Monitor (FM), analysts are bound to revisit bribery in the fiscal domain.

Breaking Fiscal-Corruption nexus has lately become top priority for other international/multilateral institutions too. These include Asian Development Bank (ADB), World Bank and Organisation for Economic Co-operation and

 
TII EDIT Apr 11, 2019
 
Golden Visa and CRS
By D P Sengupta

NIRAV Modi, the accused in the multi-million-dollar bank fraud is in the news again. Following the furor over his departure from India, the government of India cancelled his passport. In the initial days, television channels speculated his presence in New York, Hong Kong, and London. Various cases were registered

 
BULLETIN BOARD
 
New Delhi, May 17, 2019
CBDT issues clarification regarding definition of 'Fund Manager' under Section 9A(4)(b) ...
New Delhi, May 14, 2019
Tax Audit - Clauses 30C & 44 relating to GAAR & GST - CBDT further defers suspension till ...
New Delhi, Apr 25, 2019
Govt gives effect to Indo-US agreement for sharing CbC reports ...
New Delhi, Apr 25, 2019
Vacancy at the level of DCIT (OSD) and Under Secretary in Foreign Tax & Tax Research Divis...
< More News >
 
TII BRIEF
 
Paris, May 14, 2019
Unemployment rate stable at 5.3% in OECD Area...
Paris, Apr 30, 2019
Low-wage jobs fuel employment growth in OECD countries ...
New Delhi, Apr 18, 2019
CBDT invites comments on report pertaining to Profit Attribution to PE...
Paris, Apr 17, 2019
Employment rate up in 26 out of 36 OECD countries ...
Paris, Apr 12, 2019
Reforms lead to decline in average OECD labour taxes...
 
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