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NEWS FLASH
I-T - Receipts from distribution activity is not royalty in absence of dependent agent PE: ITAT (See Breaking News)
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 account of same: ITAT (See Breaking News)
DTAA - Concepts like virtual PE or Significant Economic Presence, while reflecting evolving international taxation trends, cannot be judicially read into a DTAA, absent express amendment: HC (See Breaking News)
DTAA - OECD materials and practices of other jurisdictions are not relevant against clear language in relevant DTAA: HC (See Breaking News)
I-T - Mismatches in limbs of provisions of section 271(1)(c) renders levy of penalty invalid: ITAT (See Breaking News)
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Mumbai, Dec 18, 2025 By TII News Service
I-T - Receipts from distribution activity is not royalty in absence of dependent agent PE: ITAT...
New Delhi, Dec 18, 2025 By TII News Service
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 ...
New Delhi, Dec 17, 2025 By TII News Service
DTAA - Concepts like virtual PE or Significant Economic Presence, while reflecting evolving international taxation trends, cannot be judicially r...
New Delhi, Dec 17, 2025 By TII News Service
DTAA - OECD materials and practices of other jurisdictions are not relevant against clear language in relevant DTAA: HC ...
Mumbai, Dec 17, 2025 By TII News Service
I-T - Mismatches in limbs of provisions of section 271(1)(c) renders levy of penalty invalid: ITAT...
New Delhi, Dec 16, 2025 By TII News Service
I-T - Sec 44C does not create distinction between common & exclusive head office expenditure, for purpose of deduction u/s 37: SC ...
Mumbai, Dec 16, 2025 By TII News Service
TP - Captive service provider cannot be compared to KPO, being differences in functional filter: ITAT...
Mumbai, Dec 16, 2025 By TII News Service
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...
Ahmedabad, Dec 15, 2025 By TII News Service
I-T - AO ought to have condoned delay in filing ITR for period of genuine COVID hardships: HC...
New Delhi, Dec 15, 2025 By TII News Service
I-T - If differential impact of working capital of Assessee vis-à-vis its comparables is already factored in pricing/ profitability, no further ...
New Delhi, Dec 15, 2025 By TII News Service
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: ...
Mumbai, Dec 12, 2025 By TII News Service
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...
Bengaluru, Dec 12, 2025 By TII News Service
TP - Receivable should be netted off against payable from its associated enterprises and net amount should be subject to interest determination o...
Mumbai, Dec 12, 2025 By TII News Service
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...
Bengaluru, Dec 11, 2025 By TII News Service
TP - If working capital adjustment is granted to assessee, computation of interest on overdue receivable from associated enterprises does not ari...
Mumbai, Dec 11, 2025 By TII News Service
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...
Mumbai, Dec 10, 2025 By TII News Service
I-T - Amounts paid by resident Indian distributors to non-resident software manufacturers, as consideration for resale/use of computer software t...
New Delhi, Dec 10, 2025 By TII News Service
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...
Mumbai, Dec 09, 2025 By TII News Service
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...
Mumbai, Dec 09, 2025 By TII News Service
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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