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I-T - Receipts from distribution activity is not royalty in absence of dependent agent PE: ITAT...
TP - If there was no value addition, and assessee only sought reimbursement of expenses on cost to cost basis, no ALP adjustment is permitted on ...
DTAA - Concepts like virtual PE or Significant Economic Presence, while reflecting evolving international taxation trends, cannot be judicially r...
DTAA - OECD materials and practices of other jurisdictions are not relevant against clear language in relevant DTAA: HC ...
I-T - Mismatches in limbs of provisions of section 271(1)(c) renders levy of penalty invalid: ITAT...
I-T - Sec 44C does not create distinction between common & exclusive head office expenditure, for purpose of deduction u/s 37: SC ...
TP - Captive service provider cannot be compared to KPO, being differences in functional filter: ITAT...
TP - Once TPO has found specified domestic transaction to be at arm's length, AO cannot interfere with decision of TPO and independently decide A...
I-T - AO ought to have condoned delay in filing ITR for period of genuine COVID hardships: HC...
I-T - If differential impact of working capital of Assessee vis-à-vis its comparables is already factored in pricing/ profitability, no further ...
I-T - Management fee partakes character of interest u/s 2(28A), and hence, would be exempt from taxation in India in terms of treaty provisions: ...
I-T - Tax on dividends paid by Indian companies to their foreign parents must be capped at rate prescribed under tax treaties instead of one unde...
TP - Receivable should be netted off against payable from its associated enterprises and net amount should be subject to interest determination o...
I-T - Mere entry in books of account is not determinative of liability towards income tax, as regards charter hire fees for offloading vessel and...
TP - If working capital adjustment is granted to assessee, computation of interest on overdue receivable from associated enterprises does not ari...
TP - Wide fluctuations in profit margins of same entity on a year-to-year basis would be offset by taking arithmetic mean of all comparables: ITA...
I-T - Amounts paid by resident Indian distributors to non-resident software manufacturers, as consideration for resale/use of computer software t...
TP - ALP is not price which taxpayer is charging or paying for being party in international transaction, but it is the price to be paid or charge...
TP - Price charged to non-AEs in India cannot be used as CUP for determining arm's length price of sales of finished products made to overseas AE...
TP - Exercise of jurisdiction u/s 263 to revise final assessment order passed in pursuance to directions of DRP is invalid: ITAT...
 
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