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DTAA - Without separate notification, applicability of MFN clause & benefit of restricted scope of source taxation, w.r.t. dividend income cannot be allowed, as there is no specific notification for applicability of MFN benefits into India Netherlands DTAA: ITAT (See 'Breaking News') TP- TIPS data can be used to determine ALP under CUP method: ITAT (See 'Breaking News') TP - Expenses incurred towards global sales & marketing activity has to be treated as operating cost and has to be allotted in ratio of turnover of other international transaction for determining ALP under TNMM: ITAT (See 'Breaking News') I-T - Payment made by Indian arm of foreign telecom company, to Non Resident Telecom Operators for provision of bandwidth capacity & inter-connect services, is not Royalty: ITAT (See 'Breaking News') Domicile of Origin vs Domicile of Choice: No visits to temple may prove fatal! (See 'Edit') I-T - Case deserves re-adjudication on merits of validity of agreement if assessee did not have adequate opportunity to establish bona fides of agreements into with medical practitioners: HC (See 'Breaking News') I-T - If services made available by foreign firm to payer does not fall within ambit of FTS, then payer is not liable to deduct TDS on those payments: ITAT (See 'Breaking News') TP - Once apparent mistake in order of Tribunal stood recalled, appeal challenging same does not survive for adjudication: HC (See 'Breaking News') I-T - If statute prescribes remedy, then assessee cannot be denied benefit of availing of such remedy merely because alternative remedy may be available : HC (See 'Breaking News') I-T - Sec 144C as it stood at relevant time, would have empowered AO to frame Draft Assessment Order only if variation in income returned was suggested: HC (See 'Breaking News') TP - If findings recorded by Tribunal while determining ALP are not perverse, no writ interference is warranted in same: HC (See 'Breaking News') TP - Failure to imbibe Rule 10B(2) while determining most appropriate method of benchmarking renders ALP invalid: HC (See 'Breaking News') I-T - Date on which Sec 275(1)(a) order is drawn is the date being liable to be accepted as constituting starting point from when assessee would be deemed to have knowledge of order passed by ITAT: HC (See 'Breaking News') I-T - Revenue Department is not entitled to withhold excess TDS deposited by assessee in lieu of anticipated liability: HC (See 'Breaking News') TP - Tested party normally should be least complex party to controlled transaction and there is no bar for selection of tested party either local or foreign party: HC (See 'Breaking News') TP - Bright line test is inappropriate for determining ALP in case of AMP expenses: HC (See 'Breaking News') TP - AO is not accorded any discretion in framing of order of assessment once directions have come to be framed by DRP: HC (See 'Breaking News') I-T - Mere fact that information sought through Foreign Tax and Tax Research from other jurisdictions is still awaited is no basis to keep LOC against assessee pending to curtail his fundamental rights: HC (See 'Breaking News') I-T - Interest arising in contracting state shall be exempt from tax in that State provided Income is derived and beneficially owned by bank carrying on bona fide banking business which is resident of other contracting State: HC (See 'Breaking News')
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