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Make believe 'make available' (See TII Edit) TP - TPO not justified in determining ALP as nil without applying any recognised method prescribed u/s 92C; cannot questioning commercial expediency of expenditure once actual rendition of services is established: ITAT (See Breaking News) TP - Companies functionally different from captive, limited-risk service provider, or companies lacking reliable segmental data, cannot be retained as comparables: ITAT (See Breaking News) I-T - If tax department has historically granted lower withholding tax certificates based on uncontested history of financial losses, competent authority cannot suddenly impose higher rate: HC (See Breaking News) I-T - For eligible assessee covered by Sec 144C, final assessment order must still be passed within outer limitation prescribed u/s 153 r/w/s 144C: ITAT (See Breaking News) INTL - A literal interpretation of Section 9(1)(i) applies only when capital asset explicitly situated in India is transferred; this legal fiction cannot be stretched to cover indirect transfers of foreign shares: ITAT (See Breaking News) I-T - Remittance of part of earmarked foreign grant by a Sec 12A-registered charitable society to University of Texas for collaborative research project cannot be disallowed as application of income outside India: ITAT (See Breaking News) TP - If BAPA fixes arm's length operating margin for IT and ITES transactions with covered US-based AEs, and transaction with uncovered non-US AE is undisputedly identical on FAR analysis, same BAPA margin can be adopted for uncovered AE as well: ITAT (See Breaking News) I-T - For determining limitation in DRP cases, Sec 144C & Sec 153 must be read together: ITAT (See Breaking News) Rethinking Royalty in the Digital Age - What AWS and Salesforce Judgments Mean (See TII SPECIAL) TP - Unsupported website extracts or third-party database information can override disclosures made in audited financial statements: ITAT (See Breaking News) TP - Notional interest cannot be separately added on delayed AE receivables if TNMM benchmarking with working capital adjustment is already accepted: ITAT (See Breaking News)
 
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About Us

Taxindiainternational.com (“TII”), established on April 23, 2010, is a dedicated portal on international taxation. TII was launched in response to the changing landscape of taxation in India. It happens to be the FIRST comprehensive and exhaustive online resource for the taxpayers and also tax authorities looking for well-arranged resource on Transfer Pricing, Double Taxation Tax Treaties, FDI, FEMA, PMLA, BIPA, NRI and Visa guidelines for various categories of expatriates employed in India by MNEs. 

TII is a sister portal of India’s most prestigious and popular taxation and trade portal Taxindiaonline.com (TIOL). In about to be nine years, TII has carved a niche for its quality, speed and authenticity among domestic as well as international users. It has earned the respect and confidence of many global experts of international taxation. It is a highly reliable resource for the various fora of the Indian judiciary. Its citations are frequently used by the courts in their decisions. Its well-researched articles are regularly referred to by the policy makers in India. Its recommendations are generally respected by the Ministry of Finance in India.

TII has a huge subscriber-base cutting across users community ranging from Foreign Taxation Division in the CBDT, Directorate of Transfer Pricing & International Taxation to advocates, law firms, MNEs, domestic companies and research organisations. It has an enviable team of in-house experts and Consulting Editors who keep an eye on the global trend and keep sensitising the policy makers on the future trends of transforming fiscal world.

Consulting Editor


Mr. D.P. Sengupta: Mr Sengupta, a former member of the IRS, retired as Chief Commissioner of Income Tax after more than 33 years of distinguished service. Before that he had a highly satisfying stint as Joint Secretary in the Tax Policy and Legislation division of the Central Board of Direct Taxes.He also served as Joint Secretary in the Foreign Taxation Division of the Ministry of Finance. He was the Competent Authority for India and represented India in the WP1 of the OECD. He is a well known international taxation expert and spoke at various international tax conferences.

CEO & Managing Editor

Shailendra Kumar, founder and CEO of TIOL started his career with The Indian Express Newspaper in 1990 and then moved to The Economic Times where he worked for more than five years before taking the entrepreneurial route to launch TIOL, an idea based on a business need which he realized as a financial journalist. His vision was to create a knowledge-driven company; which eased the burden on corporations and which acted as a media watchdog for Indian tax and trade policies. He spearheads the business in all of its facets, including regular interactions with various policy makers and administrators, and managing the editorial and news gathering team at TII. He is the recipient of the 2001 Outstanding Media Professional Award presented by the India International Professionals Forum.

 
 
 
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