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TP - TPO is justified in rejecting assessee's transfer pricing analysis solely due to absence of separately audited segmental results: ITAT (See Breaking News) I-T - If factual verification regarding claim of assessee that it had no PE in India in respect of offshore supplies of equipments and therefore same could not be taxed in India was not examined by AO, such calls for adjudication afresh: ITAT (See Breaking News) Germany faces skilled labour paucity: OECD (See Brief) TP - Framing transfer pricing adjustments on ad hoc basis without applying any methods prescribed therefor under Section 92C, is contrary to law, which requires adjustments to be based on prescribed methods only: ITAT (See Breaking News) TP - Benefit test can't be applied for allowability of expenses incurred on intra group services: ITAT (See Breaking News) DTAA - Fee received towards services rendered under group service agreement would not fall within definition of FTS as provided under Article 13(4) of India UK Treaty: ITAT (See Breaking News) I-T- Additions framed u/s 69 merit being quashed where no evidence exists to show that assessee loaned relevant sum of money in supposedly suspicion transaction: ITAT (See Breaking News) DTAA - GoDaddy.com LLC qualifies as resident under Article 4 of India-USA DTAA, based on principle that liability to tax includes potential taxation in hands of partners or members, even without direct imposition on entity: ITAT (See Breaking News) DTAA - Income from domain name registration does not qualify as royalty u/s 9(1)(vi) of the Act: ITAT (See Breaking News) TP - Benchmarking must focus on the nature of the technology licensed rather than the product: ITAT (See Breaking News) TP - Accrual of benefit to assessee or commercial expediency of any expenditure incurred by assessee is no basis to determine ALP of Management Service fees at NIL: ITAT (See Breaking News) I-T - If revenue & profit earned in Philippines is included in Indian Financials and has been offered to tax as per Indian Income Tax Act, no prejudice is caused to revenue so as to invoke Sec 263: ITAT (See Breaking News) TP - Resale Price Method is correctly used for benchmarking where assessee is engaged in pure trading activity, with minimal value addition & where transactions related to purchase & resale are closely interlinked: ITAT (See Breaking News) TP - Management Service Fees received by non-resident firm which constitute pure allocation of cost without any mark-up, being in nature of reimbursement of cost, is not taxable as Royalty: ITAT (See Breaking News) TP - ALP adjustment in respect of corporate guarantee given to AE shall be at 0.5%: ITAT (See Breaking News) I-T - AO shall issue NIL withholding Tax Certificate in respect of cross-cost charges as received by assessee from its AE, if cross charges paid by AE could not be construed as royalty: HC (See Breaking News) I-T- Audit objection does not alter very nature of power to assess/ reassess u/s 147, to power to review concluded assessment : HC (See Breaking News) I-T - TDS provision of section 194C shall not apply on transaction relating to catering service: ITAT (See Breaking News)
 
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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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