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NEWS FLASH
 
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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TII BREAKING NEWS
 
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
TP- TIPS data can be used to determine ALP under CUP method: ITAT
TP - Expenses incurred towards global sales & marketing activity has to be treated as operating cost and has to be allotted in ratio of
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
< More News >
 
TII SPECIAL Dec 11, 2023
 
Tax Crimes - Exchange of Information - CRS data need to include Fintech & Digital Wallets
By J B Mohapatra

INFORMATION exchange on a bilateral basis or through established multilateral conventions and protocols between and among jurisdictions, developed and sharpened over the years, are significant policy instruments to ensure transparency through efforts at nullifying regulatory arbitrage and amplifying detection probability. Legal and statutory instruments such as Double Tax

 
TII EDIT Feb 29, 2024
 
Domicile of Origin vs Domicile of Choice: No visits to temple may prove fatal!
By D P Sengupta

THIS is a fascinating story of an Indian immigrant to the UK and his links with the mother country as compared to those with the UK to determine his domicile for taxation purposes. The tax involved here is the inheritance tax and not income tax.

India had introduced an Estate

 
BULLETIN BOARD
 
New Delhi, Feb 07, 2024
CBDT notifies Tax Agreement with Govt of Samoa ...
New Delhi, Jan 31, 2024
CBDT notifies ITR-2...
New Delhi, Jan 24, 2024
Income-tax (First Amendment) Rules, 2024 - CBDT notifies income tax forms effective from A...
New Delhi, Jan 23, 2024
Circular explaining the provisions of the Finance Act, 2023 ...
< More News >
 
TII BRIEF
 
Pairs, Feb 24, 2024
G20 - Merchandise trade growth flattens but services pick up in Q4 ...
New Delhi, Feb 01, 2024
FDI inflow between 2014-23 stands at USD 596 bn...
New Delhi, Jan 17, 2024
India remains preferred investment destination at Davos...
Paris, Dec 14, 2023
G20 GDP inches up by 0.7% in Q3...
Paris, Dec 06, 2023
Energy crisis drives fall in tax levels in OECD countries ...
 
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