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DTAA -LTCG from grandfathered sales & long-term capital loss from non-grandfathered sales, constitute distinct transactions & separate sources of income; assessee can apply I-T Act or DTAA separately for separate transaction: ITAT (See Breaking News)

TP - For purposes of determination of market value of transfer of electricity from eligible unit to non-eligible unit is to be taken at market value at which electricity company charges from consumers: ITAT (See Breaking News)

DTAA - Maintenance support services, education & training services, being intrinsically linked to software sold by assessee, the income therefrom cannot be treated as Fees for technical support: ITAT (See Breaking News)

TP - If cost allocation Key on 'headcount basis' was duly examined and accepted by TPO to be at ALP in transfer pricing proceedings u/s 92CA(3), same cannot be subjected to retest by AO: ITAT (See Breaking News)

I-T - Condonation of delay should not be used as anticipated benefit for government departments and unless department has reasonable and acceptable genuine reason for delay with bona fide efforts: ITAT (See Breaking News)

I-T - Merely having Indian address is not sufficient to demonstrate business connection through which activities have been carried on in India and which has led to earning of income: ITAT (See Breaking News)

TP - CUP method can be applied in respect of such transactions only, where products of similar nature have been sold to unrelated parties, within same month & same country: ITAT (See Breaking News)

TP - If NIC Codes, functional filter, and profit margin of two companies are different, then they cannot be taken as comparables for purpose of calculating ALP: ITAT (See Breaking News)

I-T - Receipts earned by way of subscription towards provision of software-based information security solutions are business profits, not chargeable to tax in India in absence of PE: ITAT (See Breaking News)

TP - Captive service provider rendering services on cost-plus basis to its AE, can be compared to multi dimensional entity having huge brand value: ITAT (See Breaking News)

TP - Existence of 'arrangement' is condition precedent to trigger Sec 80IA(10) and in its absence, business transacted between eligible units and its AE are not covered within Specified Domestic Transactions u/s 92BA: ITAT (See Breaking News)

TP - Mere assertion of adoption of 'other method' under Rule 10AB is not sufficient for valid transfer pricing adjustment: ITAT (See Breaking News)

I-T-Re-assessment not tenable where based on incomplete assessment of submitted documents & where no evidence is submitted to prove inadequate creditworthiness or that transaction was not genuine: ITAT (See Breaking News)

TP - Deduction is available for reversal of provision of doubtful debts which was created and offered to tax during earlier assessment years: ITAT (See Breaking News)

DTAA - Health & Education Cess cannot be levied on tax determined under DTAA, as tax rate under DTAA is fixed & cannot be further increased by Cess or surcharge: ITAT (See Breaking News)

I-T- If provision for doubtful debts was reduced by corresponding amount from gross trade receivables on asset side, same will amount to write off which is not hit by clause (i) of the Explanation (I) to Sec 115JB: ITAT (See Breaking News)

TP - If loss of electricity Board is affected by extraordinary circumstances which are not in existence in close distribution environment, then standard loss prevailing in industry shall be taken as benchmark: ITAT (See Breaking News)

I-T - DDT is paid by domestic company resident in India, and it is tax on its income and not tax paid on behalf of shareholder, hence domestic company u/s 115O does not enter domain of DTAA at all: ITAT (See Breaking News)

International tax beyond Donald Trump (See TII Edit)

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