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INTL TAXATION INTL MISC TP FDI LIBRARY VISA BIPA NRI
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TP - Writ Courts should not intervene into factual disputes relating to fixation of average rate of royalty receivable upon rendering of technical services, unless appellate remedies are exhausted: HC (See 'Breaking News') I-T - No penalty is leviable u/s 271(1)(c) for rejection of bona fide claims regarding taxability of overseas receipts in form of cost sharing arrangements without any mark up: HC (See 'Breaking News') TP - Treatment of certain expenses as operating revenue, for purpose of ALP determination, need not be decided u/s 260A being fact finding exercise - YES: HC (See 'Breaking News') TP - Outstanding receivables from AEs cannot be re-characterized as 'short term loan', without examining its impact on working capital of Indian taxpayer entity: ITAT (See 'Breaking News') TP - Failure to adopt correct margin of comparables during course of ALP determination, merits recall of matter for limited purpose of rectifying such ommission: ITAT (See 'Breaking News') I-T - Commission paid to agents abroad, for procuring export order overseas, does not attracts withholding tax liability u/s 195: ITAT (See 'Breaking News') I-T - Service tax collection by foreign shipping companies on behalf of Government, does not form part of their gross receipts u/s 44B since having no element of profit: ITAT (See 'Breaking News') TP - No reference can be made to TPO for determination of ALP once re-opening is initiated without AO disposing of assessee's objections to reopening: HC (See 'Breaking News') I-T - Interference with Settlement Commissionís findings is not permitted under Writ jurisdiction without any visible manifest error or non application of mind in such findings: HC (See 'Breaking News') India-Qatar DTAA - Exemption granted to interest derived by govt-owned financial agencies (See Notifications in 'Intl Taxation') I-T - Failure to issue notice u/s 143(2) in re-assessment proceedings prior to finalizing re-assessment order is not condonable u/s 292BB: ITAT (See 'Breaking News') TP - Modifications in selection of comparables based on functional & RPT filter is factual analysis & need not be challenged before writ court u/s 260A: HC (See 'Breaking News') TP - CUP is inappropriate for benchmarking international transaction of import made from AEs, if there are differences in dimensions of import made against AEs & third parties: ITAT (See 'Breaking News') TP - Entities undergoing extraordinary events of merger & amalgamation which hugely affect entire business model are not good comparables: ITAT (See 'Breaking News') I-T - Furnishing revised return to rectify omissions in original return is no basis to presume concealment, warranting penalty: ITAT (See 'Breaking News') GST Law Amendments - Will Council make it more taxpayer-friendly? (See 'Cob(Web)' in 'TIOL') TP - Product dissimilarity between two manufacturing entities makes them uncomparable for benchmarking international transaction: ITAT (See 'Breaking News') TP - Once there exists transaction between two AEs, it ceases to be 'uncontrolled transaction' & so goes out of reckoning under Rule 10B(1)(e)(ii): ITAT (See 'Breaking News') TP - Mere reimbursement of pass through costs incurred by Indian entity on behalf of its overseas AE does not entail any markup without any services being rendered: ITAT (See 'Breaking News') TP - In case of foreign company, AO is required to pass draft assessment order in terms of Sec. 144C, if he proposes to make variation in its returned income: HC (See 'Breaking News') Global Forum releases 7 peer review reports (See 'TII Brief')
 
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