Thursday , February 22, 2018 |   08:35:48 IST
INTL TAXATION INTL MISC TP FDI LIBRARY VISA BIPA NRI
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TP - Incurring of losses at entity level or accrual of less economic benefit, is no criteria to determine ALP of royalty payment to AEs in respect of technical know how, at NIL: ITAT (See 'Breaking News') TP - Revised grounds filed by assessee against TP adjustment towards services related to AEs, merits no adjudication, if it is already settled as per MAP Procedure: ITAT (See 'Breaking News') TP - Accrual of tangible economic benefit to Indian entity on account of technology received from overseas AE, is no prerogative for making ALP adjustment in case of royalty paid to AEs: ITAT (See 'Breaking News') TP - No Company can be excluded from set of final comparable merely because it is making loss at operating profit level: ITAT (See 'Breaking News') I-T - Belated claim for seeking refund of excess TDS deducted mistakenly, while making payment of royalty to overseas AE, is no ground to deny such refund: HC (See 'Breaking News') TP - Assessment framed against non-existing entity is a not a procedural irregularity, which can be cured by invoking provisions of section 292B: ITAT (See 'Breaking News') TP - Failure of AO to ascertain most appropriate method for determination of ALP in relation to its international transaction with AEs, paves way for revisional jurisdiction: ITAT (See 'Breaking News') TP - When impact of receivables have been factored in working capital adjustment and thereby on its pricing/profitability vis--vis comparables, then no further adjustment is called for: ITAT (See 'Breaking News') I-T - TDS reconcilliation statement cannot be relied solely, for exercising revisional jurisdiction, without recording any impact on income by reason of international transaction in terms of Sec 92: ITAT (See 'Breaking News') Global bodies call for mobilising domestic taxes to meet SDGs (See 'TII 'Brief') TP - Reference made to TPO for computation of ALP of international transaction, in absence of approval from appropriate authority u/s 92CA, is jurisdictional defect: ITAT (See 'Breaking News') TP - ALP adjustment made in name of a non existing entity, which had been previously amalgamated by order of Writ Court, should not be sustained: ITAT (See 'Breaking News') TP - Internal CUP method benchmarked by assessee as MAM while computing ALP, cannot be disregarded, merely because of different pricing mechanism in case of AE and non-AEs: ITAT (See 'Breaking News') India, Iran sign Protocol to amend DTAA (See 'TII Brief') TP - Rate of Royalty approved by SIA / RBI will constitute CUP data, and hence international transaction comprising such royalty payment, is to be treated at ALP: ITAT(See 'Breaking News') I-T - Withholding tax liability on transponder rent & downlinking charges paid to overseas AE, cannot be determined without verifying that recipient AE had incorporated such payments its income: ITAT (See 'Breaking News')
 
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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, 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 a short time of three 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 inhouse 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.

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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 was the recipient of the 2001 Outstanding Media Professional Award presented by the India International Professionals Forum.

 
 
 
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