Thursday , February 22, 2018 |   08:38:45 IST
INTL TAXATION INTL MISC TP FDI LIBRARY VISA BIPA NRI
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TP - Incurring of losses at entity level or accrual of less economic benefit, is no criteria to determine ALP of royalty payment to AEs in respect of technical know how, at NIL: ITAT (See 'Breaking News') TP - Revised grounds filed by assessee against TP adjustment towards services related to AEs, merits no adjudication, if it is already settled as per MAP Procedure: ITAT (See 'Breaking News') TP - Accrual of tangible economic benefit to Indian entity on account of technology received from overseas AE, is no prerogative for making ALP adjustment in case of royalty paid to AEs: ITAT (See 'Breaking News') TP - No Company can be excluded from set of final comparable merely because it is making loss at operating profit level: ITAT (See 'Breaking News') I-T - Belated claim for seeking refund of excess TDS deducted mistakenly, while making payment of royalty to overseas AE, is no ground to deny such refund: HC (See 'Breaking News') TP - Assessment framed against non-existing entity is a not a procedural irregularity, which can be cured by invoking provisions of section 292B: ITAT (See 'Breaking News') TP - Failure of AO to ascertain most appropriate method for determination of ALP in relation to its international transaction with AEs, paves way for revisional jurisdiction: ITAT (See 'Breaking News') TP - When impact of receivables have been factored in working capital adjustment and thereby on its pricing/profitability vis--vis comparables, then no further adjustment is called for: ITAT (See 'Breaking News') I-T - TDS reconcilliation statement cannot be relied solely, for exercising revisional jurisdiction, without recording any impact on income by reason of international transaction in terms of Sec 92: ITAT (See 'Breaking News') Global bodies call for mobilising domestic taxes to meet SDGs (See 'TII 'Brief') TP - Reference made to TPO for computation of ALP of international transaction, in absence of approval from appropriate authority u/s 92CA, is jurisdictional defect: ITAT (See 'Breaking News') TP - ALP adjustment made in name of a non existing entity, which had been previously amalgamated by order of Writ Court, should not be sustained: ITAT (See 'Breaking News') TP - Internal CUP method benchmarked by assessee as MAM while computing ALP, cannot be disregarded, merely because of different pricing mechanism in case of AE and non-AEs: ITAT (See 'Breaking News') India, Iran sign Protocol to amend DTAA (See 'TII Brief') TP - Rate of Royalty approved by SIA / RBI will constitute CUP data, and hence international transaction comprising such royalty payment, is to be treated at ALP: ITAT(See 'Breaking News') I-T - Withholding tax liability on transponder rent & downlinking charges paid to overseas AE, cannot be determined without verifying that recipient AE had incorporated such payments its income: ITAT (See 'Breaking News')
 
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