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MLI and India (See 'TII EDIT') I-T - Penalty is not warranted if assessee failed to set off long term capital loss on a bonafide belief that in terms of Sec 10(38) only income is required to be considered: HC (See 'Breaking News) GST on July 1 - A Historic Gain & a Loss! (See 'The Cob(Web) in TIOL) CBDT signs six APAs including a bilateral one with UK (See 'TII Brief') TP - Percentage of net sales paid by assessee to its AE as licensee, for making use of technical knowhow without having any right to retain them, cannot be capitalized: ITAT (See 'Breaking News') TP - Working capital adjustment cannot be computed, without taking into consideration trade receivables during concerned year: ITAT (See 'Breaking News') TP - Written off advance given by assessee to supplier in ordinary course of business is to be treated as business loss: ITAT (See 'Breaking News') TP - Company cannot be a good comparable if unlike assessee company it has high RPT, different FY & negative net worth: ITAT (See 'Breaking News') TP - Company outsourcing substantial portion of its work is not good comparable for assessee which is providing said services on its own: ITAT (See 'Breaking News') TP - Back to back transactions at same price between AEs or by AE to independent enterprise are inherently armís length transactions: ITAT (See 'Breaking News') OECD moots Tax Progressivity to fix Globalization Backlash (See 'TII Special') TP - Adjustment is not warranted if it is held that assessee firm & another firm which supplies material to assessee are not AEs: HC (See 'Breaking News') I-T - Salary received in India for services rendered on board ship outside territorial waters, is not sufficient to give recepient country 'right to tax such income on receipt basis: ITAT (See 'Breaking News') Cabinet approves amendment in India-Netherlands SSA (See 'TII Brief') DTAA - Mere exclusion of international shipping profits from Article 7 of Indo Switzerland DTAA, can't be regarded as vesting India with right to tax international shipping profits: ITAT (See 'Breaking News') TP - RPM can be applied as MAM for determining ALP of 'purchase of finished goods from AE', only after carrying out AMP intensity adjustment in profit rate of comparables: ITAT (See 'Breaking News') GST - July 1 - Another 'Disruptive' Decision? (See 'THE COB(WEB)' in TIOL) TP - DRP can confirm, reduce or enhance variations proposed in draft order but is not empowered to remit issue back to AO/TPO u/s 144C(5): ITAT (See 'Breaking News') TP - ALP of 'management services fee' can be determined at Nil, in absence of any actual rendering of services by AE: ITAT (See 'Breaking News')
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