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INTL TAXATION INTL MISC TP FDI LIBRARY VISA BIPA NRI
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TP - Donations & provision for bad debts cannot be considered as operating item while computing PLI, without showing any nexus between them: ITAT (See 'Breaking News') I-T - Writ remedy sought for deciding jurisdiction of SCN cannot be denied per se owing to availability of alternate remedy: HC (See 'Breaking News') I-T - Indian insurance companies are liable to withhold tax at source before remitting Insurance premium to foreign re-insurance companies: ITAT (See 'Breaking News') TP - Mark up should be considered based on average speed over LIBOR charged in France rather than entire European region, for determining ALP of advances made to French company: HC (See 'Breaking News') TP - Merchant bankers being functionally dissimilar to non-binding insurance advisory service providers, cannot be compared for purposes of benchmarking: ITAT (See 'Breaking News') TP - Pure software developers are not comparables to ITES providers being of different functional profile: ITAT (See 'Breaking News') DTAA - AMC services provided post completion of installation activities at site of Indian customer do not constitute 'Installation PE' in india: ITAT (See 'Breaking News') DTAA - Tax Residency Certificate constitutes sufficient evidence for accepting status of residence as well as beneficial ownership when applying provisions of Tax Treaty: ITAT (See 'Breaking News') I-T - Treaty provisions, where beneficial to taxpayers, will override provisions of Section 206AA, upon failure of non-resident recipient to furnish PAN: ITAT (See 'Breaking News') TP - Companies engaged in diversified activities can be adopted as comparables provided their segmental results are available for verification: ITAT (See 'Breaking News') TP - Export incentives should be considered as part of turnover when working out gross profit margin in case of international transaction of exporting finished goods to AEs: ITAT (See 'Breaking News') TP - Where loan for which corporate guarantee is extended to foreign AE, is availed in local currency of its residence, then local interest rate is applicable for ALP purposes: ITAT (See 'Breaking News') GST - Credit conundrums - Overlooking them is no solution! (See 'Cob(Web)' in 'TIOL') TP - TPO cannot determine ALP on estimation basis by entertaining doubts regarding business expediency of payments for making disallowance u/s 37(1): ITAT (See 'Breaking News') TP - Closely linked transactions cannot be segregated for purpose of determining arm's length price: ITAT (See 'Breaking News') TP - Entities having huge brand image & substantial intangibles cannot be compared to captive service providers more so without segmental information: ITAT (See 'Breaking News') TP - Companies engaged in software products are not good comparables to captive software developers being functionally dissimilar: ITAT (See 'Breaking News')
 
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