Thursday , June 27, 2019 |   07:46:26 IST
INTL TAXATION INTL MISC TP FDI LIBRARY VISA BIPA NRI
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TP - Arm's length price of corporate guarantee fee charged from associated entities can reasonably be fixed @ 0.5%: ITAT (See 'Breaking News') TP - Entities which did not fulfill RPT filer should not be included in final list of comparables: ITAT (See 'Breaking News') I-T - Employees deputed to Indian subsidiary cannot be construed as Service PE, if entire salary cost was borne by such subsidiary: ITAT (See 'Breaking News') I-T - Payments made overseas for purchase of licensed software, amounts to royalty: ITAT (See 'Breaking News') TP - Rate of interest on outstanding receivables from overseas AEs should be market determined interest rate applicable to currency concerned in which loan has to be repaid: ITAT (See 'Breaking News') TP - Substantial functional dissimilarity & variation in RPT filter, calls for rejection of such entity from list of comparables: ITAT (See 'Breaking News') TP - Mere routing of money through AE for purpose of acquisition of distributorship, is not a case of advancing and hence no adjustment is warranted on account of notional interest: ITAT (See 'Breaking News') I-T - Once taxpayer had approached ARA seeking its ruling, then he must restrain from filing his returns before the ARA pronouncing such ruling: HC (See 'Breaking News') DTAA - Support services provided by Indian subsidiary of Foreign re-insurer cannot be equated to carrying on of 'reinsurance business' and hence its receipts are not taxable in India: ITAT (See 'TII Breaking News') TP - Factual exercise done by Tribunal regarding selection of comparable cannot be faulted in absence of any material disputing correctness of such finding: HC (See 'Breaking News') TP - Functional dissimilarity and mismatch of related party transaction filter, calls for exclusion of such entity from final list of comparables: ITAT (See 'Breaking News') TP - TPO is competent to determine ALP of international transactions at NIL, if prices offered by taxpayer entity is not in compliance with transfer pricing regulation: ITAT (See 'Breaking News')
 
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