Tuesday , October 4, 2022 |   09:45:51 IST
INTL TAXATION INTL MISC TP FDI LIBRARY VISA BIPA NRI
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Economy Needs Synergetic Inputs to fix twin Deficits of Inflation & Rupee fall (See 'taxindiaonline' I-T - Payment received from British Airways in relation to use of 'Altea system' cannot be characterized as 'royalty', if Altea system was installed at airport and was accessable only by airlines: ITAT (See 'Breaking News') DTAA - amount received by assessee-company as proceeds from sale of software, being copyrighted article, qualifies as business income & cannot be treated as Royalty income: ITAT (See 'Breaking News') TP - Question of applying the Bright Line Test to determine existence of international transaction involving AMP expenditure does not arise: HC (See 'Breaking News') TP - TPO/DRP have to follow time limits as provided under I-T Act and entire proceedings including hearing and directions have to be issued by DRP within 9 months as contemplated u/s 144C(12): ITAT (See 'Breaking News') TP - Functional dissimilarity, presence of brand and extraordinary event taken place during relevant year on account of acquisition, renders such entity unfit for purposes of comparison: ITAT (See 'Breaking News') TP - If ALP of international transactions with AEs stands covered in favour of APA entered into by Assessee with CBDT, no adjudication remain further as far as ALP is concerned: ITAT (See 'Breaking News') A single tax with multiple governing Acts (See 'taxindiaonline') DTAA - Only consideration for development & transfer of technical plan/design gets covered under 'FTS' and not 'consideration for their management/supervision' as per Article 12(4)(b) of India USA DTAA: ITAT (See 'Breaking News') TP - If final assessment order passed by NFAC to extent of TP adjustment is not in accordance with directions of DRP, then TP adjustment to such extent deserves to be quashed: ITAT (See 'Breaking News') I-T - Deductions contemplated u/s 10A was qua profits of eligible undertaking of taxpayer on stand-alone basis and without reference to other eligible or non-eligible units or undertakings of assessee: ITAT (See 'Breaking News') I-T - Credit for taxes paid by assessee in Japan, Swiss Federation and Malaysia is eligible for credit subject to limitation of such relief not exceeding that part of tax which is attributable to income to be taxed in Japan, Swiss and Malaysia: ITAT (See 'Breaking News') A peep into President Biden's Fiscal-verse! (See 'TII EDIT') Govt constitutes collegium for deciding deferment of appeals before the Appellate Tribunal or the jurisdictional High Court by the Assessing Officer (See 'Bulletin Board ') Trade Based Money-Laundering: A Critical Analysis (See 'taxindiaonline') 'Crooked' Recession looms large! Let curve of your smile set it 'straight'! (See 'taxindiaonline') TP - Computation of Arm's Length Price based on incorrect assumption of services rendered, would cause prejudice to computation of ALP - case remanded: ITAT (See 'Breaking News')
 
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