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TP - Comparable company merits being excluded from list of comparables, where it is functionally dis-similar in comparison to assessee: ITAT (See 'Breaking News') DTAA -In absence of a clause in DTAA not dealing with a particular item of income, a payment should not be regarded as residuary income but as business income which is not chargeable to tax in India, in the absence of a PE of the non-resident in India: ITAT (See 'Breaking News') Switzerland hosts Indian trade delegation; eye on enhancing ties following TEPA (See Brief) TP - Comparable company merits being excluded on account of diversified operations, lack of segmental information, and differences in turnover and services compared to the assessee: ITAT (See 'Breaking News') I-T - DRP's order upholding draft order without giving assessee an opportunity of presenting evidence, is unsustainable: ITAT (See 'Breaking News') DTAA -Revenue earned by assessee-company from supply of software & maintenance thereof, cannot be deemed to be Royalty as per I-T Act & India-UK DTAA: ITAT (See 'Breaking News') I-T- Assessee entitled to deduction on amount paid to non-resident for expenses incurred, considering that recipient declares amount so received, in its own ITR: ITAT (See 'Breaking News') TP - Department's premise of Royalty being paid by the assessee-company to its own self, where such a payment be made to a holding company, is wholly untenable: HC (See 'Breaking News') I-T- As per trite law, an assessee cannot be expected to deduct tax at source from payments that became taxable owing to retrospective amendment: HC (See 'Breaking News') DTAA - consideration received for provision of Managerial Services, cannot be deemed to be Royalty or taxed as such, where no transfer of knowledge or expertise is involved: ITAT (See 'Breaking News') TP - Where TPO's report is limited to determination of ALP only, then the AO cannot travel beyond determination of ALP: ITAT (See 'Breaking News') I-T- Once profit from business increases, it will correspondingly increase amount of deduction claimed u/s 10A; even if business profit is increased there will be no change in assessee's taxable income: ITAT (See 'Breaking News')
 
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About Us

Taxindiainternational.com (“TII”), established on April 23, 2010, is a dedicated portal on international taxation. TII was launched in response to the changing landscape of taxation in India. It happens to be the FIRST comprehensive and exhaustive online resource for the taxpayers and also tax authorities looking for well-arranged resource on Transfer Pricing, Double Taxation Tax Treaties, FDI, FEMA, PMLA, BIPA, NRI and Visa guidelines for various categories of expatriates employed in India by MNEs. 

TII is a sister portal of India’s most prestigious and popular taxation and trade portal Taxindiaonline.com (TIOL). In about to be nine years, TII has carved a niche for its quality, speed and authenticity among domestic as well as international users. It has earned the respect and confidence of many global experts of international taxation. It is a highly reliable resource for the various fora of the Indian judiciary. Its citations are frequently used by the courts in their decisions. Its well-researched articles are regularly referred to by the policy makers in India. Its recommendations are generally respected by the Ministry of Finance in India.

TII has a huge subscriber-base cutting across users community ranging from Foreign Taxation Division in the CBDT, Directorate of Transfer Pricing & International Taxation to advocates, law firms, MNEs, domestic companies and research organisations. It has an enviable team of in-house experts and Consulting Editors who keep an eye on the global trend and keep sensitising the policy makers on the future trends of transforming fiscal world.

Consulting Editor


Mr. D.P. Sengupta: Mr Sengupta, a former member of the IRS, retired as Chief Commissioner of Income Tax after more than 33 years of distinguished service. Before that he had a highly satisfying stint as Joint Secretary in the Tax Policy and Legislation division of the Central Board of Direct Taxes.He also served as Joint Secretary in the Foreign Taxation Division of the Ministry of Finance. He was the Competent Authority for India and represented India in the WP1 of the OECD. He is a well known international taxation expert and spoke at various international tax conferences.

CEO & Managing Editor

Shailendra Kumar, founder and CEO of TIOL started his career with The Indian Express Newspaper in 1990 and then moved to The Economic Times where he worked for more than five years before taking the entrepreneurial route to launch TIOL, an idea based on a business need which he realized as a financial journalist. His vision was to create a knowledge-driven company; which eased the burden on corporations and which acted as a media watchdog for Indian tax and trade policies. He spearheads the business in all of its facets, including regular interactions with various policy makers and administrators, and managing the editorial and news gathering team at TII. He is the recipient of the 2001 Outstanding Media Professional Award presented by the India International Professionals Forum.

 
 
 
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