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TP - Entity engaged in rendering payroll activity and routine IT services cannot be treated as good comparable for BPO service provider: HC (See 'Breaking News') TP - Entity cannot be excluded merely because no segmental data with respect to its underrate income schemes was present during the year under consideration: HC (See 'Breaking News') TP - Difference in accounting period is no ground to hold a functionally similar company as non comparable: ITAT (See 'Breaking News') I-T - Receipts pertaining to a shipping company in nexus with prospecting, extraction or production of mineral oil, will be assessable u/s 44BB: ITAT (See 'Breaking News') Doctrine of Umbilical Cord puts onus on Executive to protect Supreme Court for own survival! (See 'COB( WEB)' in 'TIOL') I-T - Commission payments remitted directly to overseas agents for procuring business abroad, does not attract withholding tax liability u/s 195: ITAT (See 'Breaking News') TP - Rejection of comparables adopted by taxpayer for purposes of benchmarking international with its AEs, does not amounts to concealment for levy of penalty: ITAT (See 'Breaking News') TP - Addition of TP adjustment in hands of Assessee is no basis to levy penalty, without recording any satisfaction as concealment or furnishing of inaccurate particulars: ITAT (See 'Breaking News') DTAA - Foreign employer having PE in India has to withhold TDS on salary paid to expatriates irrespective of their stay in India, even if salary is exempt under treaty provisions: ITAT (See 'Breaking News') TP - Volatility in the margin of company, caused due to revenue recognition method followed by such company, does not calls for its exclusion from list of comparables: ITAT (See 'Breaking News') TP - Variation in prices realized from unrelated parties against those of prices charged to AEs, is no basis to make TP adjustment, if aggregate difference in ALP is within tolerance range of 5 per cent: ITAT (See 'Breaking News') TP - Crystallization of demand on income assessed in hands of taxpayer, should not be made in draft assessment order u/s 143(3) r/w/s 144C(1): ITAT (See 'Breaking News') TP - Royalty paid for exports to AE cannot be determined at NIL, if export made to AEs was undertaken on principal to principal basis and Indian entity is acting as licensed manufacturer: ITAT (See 'Breaking News') TP - Merely because tested party and comparable selected for purposes of banchmarking, were engaged in ITES segment, will not make them comparable: HC (See 'Breaking News') TP - Acceptance of return filed by overseas AEs, by itself does not merits acceptance of price paid to those AEs by Indian entity in international transaction as at Arm's Length: ITAT (See 'Breaking News')
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