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I-T- DTAA does not get triggered at all when a domestic company pays DDT u/s 115-O of the Act : ITAT (See 'Breaking News') TP - Arm's length computation of corporate guarantees issued by assessee in favour of its AEs abroad taken at 1% which has been approved for earlier A.Ys, cannot be disturbed in absence of contrary: ITAT (See 'Breaking News') TP - Adjustment made to interest rate by treating Letter of Credit as bank guarantee cannot be accepted: ITAT (See 'Breaking News') I-T-The commission income earned by foreign agents cannot be termed to have incurred or arisen in India, and therefore, is not taxable in India: ITAT (See 'Breaking News') TP- AO does not have the jurisdiction to propose any transfer pricing adjustment in case where he has not made any reference to the TPO: ITAT (See 'Breaking News') TP - Letter of comfort issued by assessee in respect of credit facility extended to its AEs by banks outside India, which was admitted as liability having bearing on assets, constitutes international transaction: ITAT (See 'Breaking News') DTAA - Payment made to UAE entities cannot be deemed to be Fees for Technical Service, where no technical knowledge, know-how or skill is made available: ITAT (See 'Breaking News') DTAA - Payments made from India to UAE are not taxable in India, where UAE-based recipient company has no PE in India, as mandated under India - UAE DTAA: ITAT (See 'Breaking News') DTAA - Payment received on account of subscription, professional and training services cannot be deemed to be Fees for Technical service and be taxed as Royalty, where no technical know-how is made available: ITAT (See 'Breaking News') I-T- Onus of establishing receipt of services from Associated Enterprise has to be discharged on year to year basis by assessee company: ITAT (See 'Breaking News') I-T - If assessee is not making available underlying know-how with respect to research projects as enumerated under DTAA & MOU, then receipts under head ILP membership cannot be reckoned as FIS: ITAT (See 'Breaking News')
 
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Mumbai, Apr 24, 2024 By TII News Service
I-T- DTAA does not get triggered at all when a domestic company pays DDT u/s 115-O of the Act : ITAT ...
Ahmedabad, Apr 24, 2024 By TII News Service
TP - Arm's length computation of corporate guarantees issued by assessee in favour of its AEs abroad taken at 1% which has been approved for earl...
Ahmedabad, Apr 23, 2024 By TII News Service
TP - Adjustment made to interest rate by treating Letter of Credit as bank guarantee cannot be accepted: ITAT...
Ahmedabad, Apr 23, 2024 By TII News Service
I-T-The commission income earned by foreign agents cannot be termed to have incurred or arisen in India, and therefore, is not taxable in India: ...
Kolkata, Apr 23, 2024 By TII News Service
TP- AO does not have the jurisdiction to propose any transfer pricing adjustment in case where he has not made any reference to the TPO: ITAT ...
Mumbai, Apr 22, 2024 By TII News Service
TP - Letter of comfort issued by assessee in respect of credit facility extended to its AEs by banks outside India, which was admitted as liabili...
New Delhi, Apr 22, 2024 By TII News Service
DTAA - Payment made to UAE entities cannot be deemed to be Fees for Technical Service, where no technical knowledge, know-how or skill is made av...
New Delhi, Apr 22, 2024 By TII News Service
DTAA - Payments made from India to UAE are not taxable in India, where UAE-based recipient company has no PE in India, as mandated under India - ...
New Delhi, Apr 19, 2024 By TII News Service
DTAA - Payment received on account of subscription, professional and training services cannot be deemed to be Fees for Technical service and be t...
New Delhi, Apr 19, 2024 By TII News Service
I-T- Onus of establishing receipt of services from Associated Enterprise has to be discharged on year to year basis by assessee company: ITAT...
Mumbai, Apr 19, 2024 By TII News Service
I-T - If assessee is not making available underlying know-how with respect to research projects as enumerated under DTAA & MOU, then receipts und...
Ahmedabad, Apr 18, 2024 By TII News Service
TP - If assessee has suo-moto offered guarantee commission and no inherent risk arises to financial services utilized by AE from assessee, then n...
Hyderabad, Apr 18, 2024 By TII News Service
INTL - Expenses incurred by a non-resident individual towards obtaining Special Power of Attorney & anciliary expenses, for purpose of transferri...
New Delhi, Apr 17, 2024 By TII News Service
TP - ALP adjustment cannot be made with reference to entire turnover of assessee and ought to be restricted to value of international transaction...
New Delhi, Apr 17, 2024 By TII News Service
TP - Land acquisition matters where market value is determined on bases of certain parameters peculiar to parties & property, CUP method is more ...
Mumbai, Apr 17, 2024 By TII News Service
TP - Once assessment record is transferred by faceless unit to AO having territorial jurisdiction, then no action u/s 263 is possible with PCIT w...
Mumbai, Apr 16, 2024 By TII News Service
TP - Not adopting mandatorily prescribed methods to determine ALP in respect of fees of technical services payable by Assessee to its AE, make en...
New Delhi, Apr 16, 2024 By TII News Service
TP - If any third party rate is not considered for particular date of contract due to non availability of data, would not enable TPO to reject me...
New Delhi, Apr 16, 2024 By TII News Service
TP - If there is difference between ALP determined by particular method & transfer price adopted by assessee, it may warrant the transfer pricing...
New Delhi, Apr 15, 2024 By TII News Service
DTAA - As per settled law, consideration for resale/use of computer software through EULA or distribution agreement, is not Royalty for use of co...
 
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