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I-T - Once income from supply of plant & equipment is held to be not taxable in India, since sale transaction was completed outside India, same l...
I-T - Gain on MTM which has been held to be treated as income of assessee in order passed u/s 154 can be reversed in case MTM loss is held to be ...
TP - Reimbursement received at cost does not require any mark-up: ITAT...
TP - AMP expenditure is not unilateral and out of some discernible arrangement which is reflected in concert action between assessee and AE: ITAT...
TP - Adjustment on AMP and disallowance of reimbursements deleted; no international transaction established: ITAT...
I-T - Department must issue necessary instructions to all Assessment Units/Penalty Units as per Sec 144B(3), to ensure that AO who provides for V...
I-T - Absence of interest does not derogate from assessee substantive right to receive refund, which he would have otherwise been entitled to, ha...
TP - ALC at which power is procured by non-eligible units from SEB is most appropriate ALP to bench mark specified domestic transactions: ITAT...
TP - Benchmarking of payment & receipt of revenue can't be combined to benchmark transactions adopting same OP/OC or OP/OR, and said exercise mus...
TP - Working capital adjustment can't be denied merely due to absence of detailed working capital cycle data and adjustment should be granted bas...
TP - TPO is justified in rejecting assessee's transfer pricing analysis solely due to absence of separately audited segmental results: ITAT ...
I-T - If factual verification regarding claim of assessee that it had no PE in India in respect of offshore supplies of equipments and therefore ...
TP - Framing transfer pricing adjustments on ad hoc basis without applying any methods prescribed therefor under Section 92C, is contrary to law,...
TP - Benefit test can't be applied for allowability of expenses incurred on intra group services: ITAT...
DTAA - Fee received towards services rendered under group service agreement would not fall within definition of FTS as provided under Article 13(...
I-T- Additions framed u/s 69 merit being quashed where no evidence exists to show that assessee loaned relevant sum of money in supposedly suspic...
DTAA - GoDaddy.com LLC qualifies as resident under Article 4 of India-USA DTAA, based on principle that liability to tax includes potential taxat...
DTAA - Income from domain name registration does not qualify as royalty u/s 9(1)(vi) of the Act: ITAT ...
TP - Benchmarking must focus on the nature of the technology licensed rather than the product: ITAT ...
TP - Accrual of benefit to assessee or commercial expediency of any expenditure incurred by assessee is no basis to determine ALP of Management S...
 
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