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NEWS FLASH
Germany faces skilled labour paucity: OECD (See Brief)
TP - Framing transfer pricing adjustments on ad hoc basis without applying any methods prescribed therefor under Section 92C, is contrary to law, which requires adjustments to be based on prescribed methods only: ITAT (See Breaking News)
TP - Benefit test can't be applied for allowability of expenses incurred on intra group services: ITAT (See Breaking News)
DTAA - Fee received towards services rendered under group service agreement would not fall within definition of FTS as provided under Article 13(4) of India UK Treaty: ITAT (See Breaking News)
I-T- Additions framed u/s 69 merit being quashed where no evidence exists to show that assessee loaned relevant sum of money in supposedly suspicion transaction: ITAT (See Breaking News)
DTAA - GoDaddy.com LLC qualifies as resident under Article 4 of India-USA DTAA, based on principle that liability to tax includes potential taxation in hands of partners or members, even without direct imposition on entity: ITAT (See Breaking News)
DTAA - Income from domain name registration does not qualify as royalty u/s 9(1)(vi) of the Act: ITAT (See Breaking News)
TP - Benchmarking must focus on the nature of the technology licensed rather than the product: ITAT (See Breaking News)
TP - Accrual of benefit to assessee or commercial expediency of any expenditure incurred by assessee is no basis to determine ALP of Management Service fees at NIL: ITAT (See Breaking News)
I-T - If revenue & profit earned in Philippines is included in Indian Financials and has been offered to tax as per Indian Income Tax Act, no prejudice is caused to revenue so as to invoke Sec 263: ITAT (See Breaking News)
TP - Resale Price Method is correctly used for benchmarking where assessee is engaged in pure trading activity, with minimal value addition & where transactions related to purchase & resale are closely interlinked: ITAT (See Breaking News)
TP - Management Service Fees received by non-resident firm which constitute pure allocation of cost without any mark-up, being in nature of reimbursement of cost, is not taxable as Royalty: ITAT (See Breaking News)
TP - ALP adjustment in respect of corporate guarantee given to AE shall be at 0.5%: ITAT (See Breaking News)
I-T - AO shall issue NIL withholding Tax Certificate in respect of cross-cost charges as received by assessee from its AE, if cross charges paid by AE could not be construed as royalty: HC (See Breaking News)
I-T- Audit objection does not alter very nature of power to assess/ reassess u/s 147, to power to review concluded assessment : HC (See Breaking News)
I-T - TDS provision of section 194C shall not apply on transaction relating to catering service: ITAT (See Breaking News)
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