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DTAA - Claim of benefit in Article 13(4) of India-Singapore DTAA does not qualify as deduction, relief or exemption, as it allocates taxing rights vis-a-vis capital gains to Singapore; provisions of Explanation 2(b) to Section 147 inapplicable here: HC (See 'Breaking News') TP - Amounts paid by resident Indian end- users/distributors to non-resident computer software manufacturers & suppliers, as consideration for resale/use of computer software through EULAs/distribution agreements, is not royalty for use of copyright in computer software: ITAT (See 'Breaking News') TP - If assessee's main activity is marketing, whereas all ownership over product & power to accept/reject order with pricing remains with AE, then profile of assessee cannot be considered as 'reseller': ITAT (See 'Breaking News') TP - Adjustment on account of interest for entire period of delay beyond 60 days cannot be treated as separate international transaction of trading debt arising during course of business: ITAT (See 'Breaking News') DTAA - payment received by assessee from its customer is held to be from sale of software products/licenses which does not qualify as royalty: ITAT (See 'Breaking News') TP - As per settled law, AO cannot pass final order without valid reference to TPO; concurrently, TPO cannot commence proceedings after final order is passed: ITAT (See 'Breaking News') Budget 2023: No room for 2-Pillar Solution? (See 'TII Edit') Time limit for furnishing TP report reduced (See 'TII Brief') TDS u/s 196A - Tax Treaty benefits to be allowed (See 'TII Brief') FB proposes to omit double taxation on distribution of income to non-resident ODI holders (See 'TII Brief') Sec 44BB - Presumptive tax for non-resident - No set of brought forward loss to be allowed (See 'TII Brief') Deeming provision of Sec 9 extended to gift received by non-ordinarily resident (See 'TII Brief') Personal Income Tax - income slabs reduced to 5 Cigarettes - NCCD on specified cigarettes to be revised - 16% hike in prices Personal Income Tax - sops for middle class - those with income upto Rs 5 lakhs - rebate limit increased to Rs 7 lakhs in new tax regime Govt allows carry forward of losses on strategic disinvestment Salaried class and pensioners - standard deduction under new tax regime - Rs 52500/- standard deduction for income of Rs 15 lakhs Personal Income Tax - highest surcharge rate reduced to 25% in new tax regime
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