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DTAA - Merely because assessee (tax resident of Mauritius) availed loans from its holding company to invest in shares of Indian entity, ipso facto, is no reason to treat assessee as conduit company: ITAT (See 'Breaking News') TP - Action of TPO of applying CUP method and at same considering value of such transaction as Nil in absence of comparable uncontrolled transactions, is in itself contradictory: ITAT (See 'Breaking News') TP - company which outsources all its activities to other service providers, cannot be comparable for company whose services are rendered by its own employees: ITAT (See 'Breaking News') Tax Congress 2022: Time is ripe to get in bed with New Income Tax Code! (See 'taxindiaonline') DTAA - burden of assessee cannot be discharged just by giving some incomplete & incoherent details of this entity & copies of some documents in foreign language: ITAT (See 'Breaking News') I-T - Managerial services charges paid by assessee to its non-resident AEs is not liable to TDS under provisions of section 195, in absence of 'make available' of any expertise: ITAT (See 'Breaking News') TP - Merely because foreign company had financial interest, it could not be presumed that AMP expenses incurred by assessee were at instance or on behalf of foreign company: ITAT (See 'Breaking News') TP - Commission paid by assessee to its AE as per relevant agreement, cannot be determined at NIL, without any sufficient basis: ITAT (See 'Breaking News') TP- Simply because ratio of employee cost and depreciation of assessee to revenue under trading segment is more in comparison with some of its comparables, that would not thwart application of RPM: ITAT (See 'Breaking News') TP - as per settled principle of law, in absence of any definition for a particular term in a statute, meaning of term understood in common parlance is to be adopted: ITAT (See 'Breaking News') TP - Power of revision can neither be exercised where CIT (A) has already disposed off the matter nor where CIT is only at disagreement with the view taken by AO, which is one of several views possible: ITAT (See 'Breaking News') I-T - Withholding tax liability on premium payable on FCCB and borne by assessee, would go to increase cost of asset and accordingly depreciation is allowable thereon: ITAT (See 'Breaking News') Quo Vadis Pillar one? (See 'TII Edit') TP - service of directions by DRP in terms of Rule 11 of Income-tax (Dispute Resolution Panel) Rules, 2009, is only procedural requirement put in place by delegated legislation, without any corresponding provision in the enactment: ITAT (See 'Breaking News') DTAA - TDS needn not be deducted in respect of payment which is not found to be of nature of royalty; disallowance u/s 40(a)(ia) is unwarranted: ITAT (See 'Breaking News')
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