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INTL TAXATION INTL MISC TP FDI LIBRARY VISA BIPA NRI
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TP - Company engaged into diversified activities being a big brand, cannot be compared to a routine captive service provider, that too in absence of segmental reporting: ITAT(See 'Breaking News') TP - AMP expenses incurred by Indian entity for promotion of its business cannot be termed as 'international transaction', in absence of any of its arrangement with overseas AEs: ITAT (See 'Breaking News') TP - Extra ordinary events witnessed by a company during particular year, does not calls for its exclusion for comparable analysis, without probing its impact of profitability: ITAT(See 'Breaking News') TP - Company having fluctuating operating margin, are no good comparable for purposes of benchmarking: ITAT(See 'Breaking News') I-T - Interest paid on ECBs lend by foreign branch of resident banking company, attracts no TDS liability u/s 195: ITAT (See 'Breaking News') I-T - Freight charges for import made from AEs attracts no withholding tax liability u/s 195, merely because telegraphic transfer of remittances towards AEs were made from bank in India: ITAT (See 'Breaking News') TP - Writ Court should not entertain an issue framed before it, when such an issue is beyond the one as raised before the Tribunal: HC (See 'Breaking News') TP - Rendering of common ITES services will not make two enties comparable to each other, unless their business model are similar: HC (See 'Breaking News') TP - No ALP adjustment is warranted on model fees & royalty, if no products are sold to AEs on which royalty is payable and entire amount of royalty was paid on sales made to independent enterprises: ITAT (See 'Breaking News') TP - Company engaged in multifarious activities besides tour operation and having its own brand value, cannot be considered as good comparable to a tourism company: ITAT (See 'Breaking News') I-T - Taxpayer cannot be held responsible for witholding taxes on source u/s 195 anticipating a restrospective amendment in the future: ITAT (See 'Breaking News') Investment by Foreign Portfolio Investors (FPI) in Debt - Review (See 'RBI Circular' in FDI) I-T - No NRI is permitted to open foreign bank account by using proof of identity as mentioned in Indian passport, once he has accepted foreign nationality and surrendered Indian citizenship: ITAT (See 'Breaking News') I-T - Furnishing of evidences of TDS deduction u/s 195 along with Form 15CB, is no pre-requisite for preferring appeals u/s 246, when matter relates to foreign remittances for services rendered abroad: ITAT (See 'Breaking News') TP - Written down value of cranes in books of overseas AEs, cannot be considered as ALP in an international transaction of import of cranes from those AEs: ITAT (See 'Breaking News')
 
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