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TP - If any third party rate is not considered for particular date of contract due to non availability of data, would not enable TPO to reject method adopted by assessee: ITAT (See 'Breaking News') TP - If there is difference between ALP determined by particular method & transfer price adopted by assessee, it may warrant the transfer pricing adjustment, if such variation is not within permissible tolerance range specified in I-T Act: ITAT (See 'Breaking News') PPT finally finds its space in Indian-Mauritius Tax Treaty (See 'TII SPECIAL') DTAA - As per settled law, consideration for resale/use of computer software through EULA or distribution agreement, is not Royalty for use of copyright in computer software; no taxable income arises in India; no TDS u/s 195 warranted: ITAT (See 'Breaking News') DTAA - Therefore, such payment does not give rise to any income which is taxable in India & in which case no TDS is to be deducted u/s 195 of the I-T Act : ITAT (See 'Breaking News') TP- The limitation period does not get extended by virtue of transfer of the case record internally from FAO to JAO: ITAT (See 'Breaking News') I-T- The credit available to assessee may be eligible as a refund where consideration on which tax has been deducted is not taxable: ITAT (See 'Breaking News') TP - Once Specified Domestic Transactions have been omitted from the I-T Act, then no transfer pricing adjustment can be made in this regard by invoking provisions of Section 92BA: ITAT (See 'Breaking News') TP - Explanatory notes to provisions of Finance Act only explain the substance of provisions of concerned Finance Act relating to Direct taxes & may serve as external aid to interpretation of Finance Act but cannot be considered to be issued u/s 119 of I-T Act: ITAT (See 'Breaking News') TP - Power of revision cannot be invoked in a manner which is contrary to directions issued u/s 119 of I-T Act: ITAT (See 'Breaking News') Blue Dot Network, hosted by OECD, begins global certification for quality infrastructure (See Brief) I-T-It is in the interest of justice to admit the additional evidence and remand the issue raised relating to disallowance back to AO for denovo adjudication after granting appellant a reasonable opportunity of being heard : ITAT (See 'Breaking News') I-T- Once the expenses have no nexus with the units eligible for deduction, such expenses can be allocated to units for the purpose of computing deduction w/s 80IB/801C of the Act : ITAT (See 'Breaking News') I-T- Assessment order passed in the name of a non-existent entity is void ab initio: ITAT (See 'Breaking News') I-T- CIT (A) is justified in treating assessee's expenditure as revenue expenditure when assessee's new business is an extension of the existing business : ITAT (See 'Breaking News')
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