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I-T - Receipts for use or right to use of satellite transponders for rendering either Telecommunication Services or Satellite Services do not constitute royalty: HC (See Breaking News) DTAA - Service income cannot be treated as royalty when no evidence is presented to demonstrate that services provided did not result in transfer of technical knowledge or skill: ITAT (See Breaking News) I-T - GST amount can't be taken into consideration while determining deemed business income of foreign shipping company as per Sec 44B(1): ITAT (See Breaking News) DTAA - Where interest adjustment did not arise from any contractual obligation & is purely notional, it cannot be taxed under Article 11 of India-Germany DTAA: ITAT (See Breaking News) DTAA - Neither the India-Thailand DTAA nor domestic law bars set-off of losses of a Permanent Establishment against income of it's Head Office; consistency in findings must be maintained where facts remain unchanged: ITAT (See Breaking News) I-T - AO is not correct in levying penalty in assessee's case when taxability of quantum issue is debatable and for reason that claim made by assessee in AO's opinion is not allowable: ITAT (See Breaking News) TP - Upon receipt of directions issued u/s 144C(5), AO shall supposed to complete assessment inconformity with directions of DRP: ITAT (See Breaking News) I-T - Sanction for re-assessment after three years from end of relevant AY, must come from PCIT or Principal DGIT, and not from the CIT : ITAT (See Breaking News) I-T - Period of limitation can't be extended under Explanation (ix) to Sec 153B to frame assessment based on reference which is contrary to limitations as expressly specified under relevant treaty protocol: ITAT (See Breaking News) I-T- Lower authorities erred in denying refund merely because ITR was filed in response to notice u/s 148 & not u/s 139: ITAT (See Breaking News) I-T - Applicability of Sec 151 in terms of determining specified authority to seek necessary approval will arise once period of limitation is determined and crystallised by AO u/s 149: ITAT (See Breaking News) TP- Burden Lies on Assessee to Establish Currency of Loan for TP Adjustment: ITAT (See Breaking News) TP - Once TPO has passed order without making any adjustments, then AO could not have assumed jurisdiction to reopen assessment based on same facts in absence of new tangible material: HC (See Breaking News) I-T - Income Tax Act does not prohibit from first setting off STCG with STT against STCL with STT and then allow set off against STCG without STT: ITAT (See Breaking News) I-T - Issue of excess DDT paid u/s 115-O, being independent of assessment of total income u/s 143(3), must be adjudicated in separate appeal u/s 246A: ITAT (See Breaking News) Trump uses Biden's cards to trump India (See TII Edit)
 
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Breaking News
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I-T - Receipts for use or right to use of satellite transponders for rendering either Telecommunication Services or Satellite Services do not con...
DTAA - Service income cannot be treated as royalty when no evidence is presented to demonstrate that services provided did not result in transfer...
I-T - GST amount can't be taken into consideration while determining deemed business income of foreign shipping company as per Sec 44B(1): ITAT ...
DTAA - Where interest adjustment did not arise from any contractual obligation & is purely notional, it cannot be taxed under Article 11 of India...
DTAA - Neither the India-Thailand DTAA nor domestic law bars set-off of losses of a Permanent Establishment against income of it's Head Office; c...
I-T - AO is not correct in levying penalty in assessee's case when taxability of quantum issue is debatable and for reason that claim made by ass...
TP - Upon receipt of directions issued u/s 144C(5), AO shall supposed to complete assessment inconformity with directions of DRP: ITAT...
I-T - Sanction for re-assessment after three years from end of relevant AY, must come from PCIT or Principal DGIT, and not from the CIT : ITAT ...
I-T - Period of limitation can't be extended under Explanation (ix) to Sec 153B to frame assessment based on reference which is contrary to limit...
I-T- Lower authorities erred in denying refund merely because ITR was filed in response to notice u/s 148 & not u/s 139: ITAT ...
I-T - Applicability of Sec 151 in terms of determining specified authority to seek necessary approval will arise once period of limitation is det...
TP- Burden Lies on Assessee to Establish Currency of Loan for TP Adjustment: ITAT...
TP - Once TPO has passed order without making any adjustments, then AO could not have assumed jurisdiction to reopen assessment based on same fac...
I-T - Income Tax Act does not prohibit from first setting off STCG with STT against STCL with STT and then allow set off against STCG without STT...
I-T - Issue of excess DDT paid u/s 115-O, being independent of assessment of total income u/s 143(3), must be adjudicated in separate appeal u/s ...
I-T - Sale of ‘off-the-shelf' software under non-exclusive license does not attract TDS liability u/s 195: HC ...
TP - AO's failure to incorporate DRP's directions is erroneous, however it does not render the entire assessment order void: ITAT ...
TP - Goods supplied by low risk distributor without any value addition, without incurring any cost on account of finance charges, can be benchmar...
TP - ALP of management fees paid to AEs can't be taken at NIL, for failure of assessee to establish commercial benefit out of such transaction: I...
I-T - Cost-to-cost reimbursement of salary of seconded employees without any markup, without having element of profit, is not taxable in hands of...
 
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