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INTL TAXATION INTL MISC TP FDI LIBRARY VISA BIPA NRI
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I-T - Appeal under international transaction can be dismissed as withdrawn, if Assessee had invoked MAP procedure of DTAA and applied before Foreign Competent authority: ITAT (See 'Breaking News') I-T - Expenses reimbursed by customers which was earlier paid on behalf of them, is to be included in gross receipt for determination of profits u/s 44BB: ITAT (See 'Breaking News') TP - Risk free and not for profit organization, will not qualify as comparable to entity engaged in marketing support for computer and mobility equipment: ITAT (See 'Breaking News') Railways eases train travel by NRIs and foreign nationals (See 'TII Brief') TP - Functionally dissimilar companies cannot be selected as comparables to each other, for purpose of ariving at ALP in international transaction: ITAT (See 'Breaking News') TP - When assessee has not carried out any R&D activity, then same cannot be taken into account for rendering services as per international transactions: ITAT (See 'Breaking News') DTAA - Overseas remittances to HO in respect of only supply of books, without making available any technology, cannot be considered as FTS within the meaning of DTAA: ITAT (See 'Breaking News') TP - Price charged or paid for services provided in a comparable uncontrolled transaction constitutes benchmark for comparison with price paid for availing of any (See 'Breaking News') TP - When all functions of assessee are similar to that of a company under private management, such company can be treated as a comparable: (See 'breaking News') TP - Extra ordinary situation faced by entity owing to collapse of its group company worldwide leading to their liquidation, demands denovo assessment before ariving at ALP: ITAT (See 'Breaking News') TP - Assessment made in case of non-existent entity, is invalid assessment: ITAT (See 'Breaking News') TP - ALP adjustment passed in name of amalgamated company, which was not existing on date of assessment, is invalid adjustment: ITAT (See 'Breaking News') TP - Company went through extraordinary event of merger which has affected its profitability, cannot be adopted as comparable for purposes of benchmarking: ITAT (See 'Breaking News') Turning 60 - Soul-searching time for DRI to remain relevant in Digital Economy (See 'THE COB(WEB)' in TIOL) TP - Amortization of software expenses and forex loss are required to be excluded, while working out operating profit of assessee from export of goods to its AE: ITAT (See 'Breaking News') TP - DRP cannot reject comparables merely because TPO had no occasion to consider them in TP proceedings, if their functional profile & financial parameters are not disputed: ITAT (See 'Breaking News') DTAA - Profits attributable to India’s operation cannot be assessed as 'business profits' in absence of PE, merely because foreign company had business connection in India: ITAT (See 'Breaking News') I-T - When Protocol to treaty itself provides for automatic application of amended provisions of treaty, even then Revenue can insist on separate notification to be issued by Central Govt about beneficial provisions of treaty - HC (See 'Breaking News') CRS Disclosure - OECD seeks inputs on Model Disclosure Rules ( See 'Brief')
 
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