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INTL TAXATION INTL MISC TP FDI LIBRARY VISA BIPA NRI
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TP - Functionally different companies cannot be compared, in absence of segmental results for comparing profit ratio from product and services: ITAT (See 'Breaking News') TP - Appeal which is filed by completely misconstruing the facts, is not maintenable: ITAT (See 'Breaking News' TP - Resale price method is most appropriate, where Assessee buys goods from AE and resells to network of distributors through Franchisees, without any value addition: ITAT (See 'Breaking News') I-T - Overseas payments made for purchasing software licenses, are liable for TDS deduction, failure of which will attract interest u/s 201: ITAT (See 'Breaking News') TP - No writ interference is warranted on issue of selection of comparables, when ITAT being last fact finding authority has given cogent reasons for same: HC (See 'Breaking News') TIOL wishes All Netizens a very Happy Diwali TP - When benefit of capital adjustment is given to Assessee, then same should also be taken into account while determining profit margin in case of comparables: ITAT (See 'Breaking News) I-T - Expenses incurred in foreign currency towards rendering technical services outside India, had to be excluded from both export turnover as well as total turnover: ITAT (See 'Breaking News') I-T - Failure of amalgamated company to challenge passing of order in name of merged company by way of raising specific ground, cannot be attributed on part of Authority: ITAT (See 'Breaking News') Over 100 preferential tax regimes dismantled across world: OECD (See 'TII Brief') Impact of Brexit - UK needs to keep close ties with EU for sustaining future living standards: OECD (See 'TII Brief') DTAA - Commission paid to UK based entity cannot be taxed as 'business profits' as per India UK DTAA, in absence of any PE of such entity in India: ITAT (See 'Breaking News') TP - Advancing of loans to AE can be treated as international transaction, if there is no element of profit and Assessee had transferred funds with intention to make investment: ITAT (See 'Breaking News') I-T - Difference between declared gross receipts and credit as per TDS certificate, does not warrant levy of penalty, when Assessee had offered differential income on receipt basis: ITAT (See 'Breaking News') I-T - When foreign honorarium was disclosed by Assessee and due taxes were paid after it was pointed that such remittance in USD was taxable, it is no fit case for levy of penalty: ITAT (See 'Breaking News') TP - If issues pertaining to FAR analysis were remanded for fresh determination of ALP, then additional ground pertaining to comparability analysis cannot be decided seperately: HC (See 'Breaking News') Risk Management and Inter-Bank Dealings - Facilities for Hedging Trade Exposures invoiced in Indian Rupees (See 'RBI Circular' in FDI)
 
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