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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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