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TP - In absence of segmental information regarding contract research & manufacturing activities, it is difficult to analyse main revenue and profit margin from contract research work: ITAT (See Breaking News) INTL - Addition framed u/s 56(2)(x) unsustainable, where difference between actual consideration & DVO-assessed value is only 4% & where ITAT benches have consistently applied the benefit of tolerance band to AY 2018–19: ITAT (See Breaking News) TP - Adjustment must be benchmarked using domestic Prime Lending Rate (PLR) & not LIBOR, where the Compulsorily Convertible Debentures are INR-denominated: ITAT (See Breaking News) TP - Transfer pricing additions not sustainable in light of bilateral & unilateral Advance Pricing Agreements entered between Assessee & CBDT: ITAT (See Breaking News) TP - TPO cannot reject TP study of assessee on ground that assessee has not availed all services agreed with AE: ITAT (See Breaking News) I-T - Genuine secondment arrangements with employer-employee relationship with, Indian entity are not subject to withholding tax: HC (See Breaking News) TP - Tolerance limit of 3% is applicable on transactions with AEs if assessee is not wholesale automobile trader: HC (See Breaking News) DTAA - Loss incurred by non-resident taxpayer from sale of non-grandfathered shares cannot be set off against capital gain, which is exempt from taxation in India: ITAT (See Breaking News) G20 GDP spikes by 0.9% in Q2 (See Brief ) DTAA - In selling of shares, possibility of rigging share prices leading to heavy capital gain and siphoning out gains to tax heavens, cannot be ruled out: ITAT (See Breaking News) TP - Functionally different companies cannot be considered as comparables: ITAT (See Breaking News) TP - If assessee has charged fees @0.5% on account of corporate guarantee provided by it, then such fee would be considered at ALP: ITAT (See Breaking News) TP - In case of default, there is always inherent risk in providing guarantees which may be reason that Finance provider insist on non-charging any commission from AE as commercial principle: ITAT (See Breaking News) TP - Corporate guarantee is not comparable to bank guarantee; commission charged cannot be evaluated based on bank guarantee rates: HC (See Breaking News) I-T - Expenses incurred by assessee in respect of Hyderabad unitis incurred for business purposes qualify to be considered u/s 37(1), if expenses are intrinsically connected with business of assessee: ITAT (See Breaking News) I-T - Export commission paid to non-residents for services rendered abroad without carrying out any business operations in India, is not taxable in India: HC (See Breaking News) TP - Adjustment made by TPO shall be restricted to international transactions alone, and not upon entire turnover/operating costs: HC (See Breaking News) I-T - Broadcasting license fees received for telecast of live matches cannot be considered as royalty: ITAT (See Breaking News) TP - TPO shall compute eligible profits as per Sec 80IA(8) with reference to rates at which respective State Electricity Boards/distribution companies has supplied electricity to end consumers in open market: 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, 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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