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Tiger Global: SC exorcises ghost of Azadi, Vodafone & CBDT Circular (See TII Edit) TP - Where clause (i) of section 92BA, was omitted vide the Finance Act, 2017, it cannot then be applied onto ongoing proceedings to frame TP adjustment: ITAT (See Breaking News) TP - Payment of technical support service charges by assessee to its AEs with mark up of 5% over and above actual cost incurred by AEs is to be accepted to be at ALP: ITAT (See Breaking News) DTAA - Filing of Form 67 is a procedural or directory requirement & not mandatory in nature: ITAT (See Breaking News) I-T - If assessee had borrowed money from partnership firm and repaid loan, without deriving any benefit, such transactions resulting in merely transferring liability of assessee can't be taxed as unexplained cash credit u/s 68: ITAT (See Breaking News) DTAA - Services of developing technologies & collaborating with academic institutions, involve transfer of technical knowledge or expertise so as to satisfy 'make available' condition required under DTAA: ITAT (See Breaking News) TP - Where impact of extended credit period is subsumed within working capital adjustment while benchmarking operating margins, separate adjustment for notional interest on receivables is unwarranted: ITAT (See Breaking News) TP - Incentive granted under state industrial policy is capital subsidy aimed at promoting industrial development in backward areas & so qualifies as capital receipt not chargeable to tax: ITAT (See Breaking News) I-T - If very foundation for issuing higher-rate TDS certificate is non-existent, certificates directing TDS deduction at higher rate on payments made to group entities, no longer survives: HC (See Breaking News) TP - DRP cannot ignore to discharge its statutory duty by merely approving conclusions of TPO without recording independent findings: HC (See Breaking News) DTAA - Payments made by Indian entities to Japan-based company being reimbursements for salaries paid to seconded employees, cannot be deemed to be Fees for Technical Services: ITAT (See Breaking News)
 
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TP - Where clause (i) of section 92BA, was omitted vide the Finance Act, 2017, it cannot then be applied onto ongoing proceedings to frame TP adj...
TP - Payment of technical support service charges by assessee to its AEs with mark up of 5% over and above actual cost incurred by AEs is to be a...
DTAA - Filing of Form 67 is a procedural or directory requirement & not mandatory in nature: ITAT ...
I-T - If assessee had borrowed money from partnership firm and repaid loan, without deriving any benefit, such transactions resulting in merely t...
DTAA - Services of developing technologies & collaborating with academic institutions, involve transfer of technical knowledge or expertise so as...
TP - Where impact of extended credit period is subsumed within working capital adjustment while benchmarking operating margins, separate adjustme...
TP - Incentive granted under state industrial policy is capital subsidy aimed at promoting industrial development in backward areas & so qualifie...
I-T - If very foundation for issuing higher-rate TDS certificate is non-existent, certificates directing TDS deduction at higher rate on payments...
TP - DRP cannot ignore to discharge its statutory duty by merely approving conclusions of TPO without recording independent findings: HC ...
DTAA - Payments made by Indian entities to Japan-based company being reimbursements for salaries paid to seconded employees, cannot be deemed to ...
TP - Objective of Sec 271G is fulfilled, if main documentation and transfer pricing study are produced, aligning with spirit of Rule 10D(3) and S...
I-T - Goodwill and intangible assets recorded in books cannot be disregarded merely because of resultant tax benefit: ITAT...
I-T - Adjustment of consideration paid towards first flat against consideration for second flat is financing mechanism to avoid refund of conside...
I-T - Receipts from provisions of support services cannot assume character of both royalty and FTS at same time: ITAT ...
TP- Re-characterization of Compulsorily Convertible Debentures (CCDs) as equity is rejected; case remanded for a fresh determination of ALP: ITAT...
TP - Amendment vide Finance Act 2021 excluding goodwill from category of depreciable assets, has prospective effect only and cannot be allowed re...
TP - Once margins after working capital adjustment fall within arm's length range, separate adjustment on account of interest on overdue receivab...
TP- Deleted the Transfer Pricing adjustment that had been added back to the book profit calculation under Section 115JB of the Income Tax Act- IT...
I-T- Income from rig hire charges are to be computed under presumptive taxation provisions of Section 44BB of the Act: ITAT ...
TP - Provision of negative lien on receivables & Participating Interest is not equivalent to providing a corporate guarantee; such arrangement is...
 
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