Friday , June 13, 2025 |   21:33:48 IST
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NEWS FLASH
 
TP - TPO is justified in rejecting assessee's transfer pricing analysis solely due to absence of separately audited segmental results: ITAT (See Breaking News) 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 same could not be taxed in India was not examined by AO, such calls for adjudication afresh: ITAT (See Breaking News) Germany faces skilled labour paucity: OECD (See Brief) TP - Framing transfer pricing adjustments on ad hoc basis without applying any methods prescribed therefor under Section 92C, is contrary to law, which requires adjustments to be based on prescribed methods only: ITAT (See Breaking News) TP - Benefit test can't be applied for allowability of expenses incurred on intra group services: ITAT (See Breaking News) DTAA - Fee received towards services rendered under group service agreement would not fall within definition of FTS as provided under Article 13(4) of India UK Treaty: ITAT (See Breaking News) 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 suspicion transaction: ITAT (See Breaking News) DTAA - GoDaddy.com LLC qualifies as resident under Article 4 of India-USA DTAA, based on principle that liability to tax includes potential taxation in hands of partners or members, even without direct imposition on entity: ITAT (See Breaking News) DTAA - Income from domain name registration does not qualify as royalty u/s 9(1)(vi) of the Act: ITAT (See Breaking News) TP - Benchmarking must focus on the nature of the technology licensed rather than the product: ITAT (See Breaking News) TP - Accrual of benefit to assessee or commercial expediency of any expenditure incurred by assessee is no basis to determine ALP of Management Service fees at NIL: ITAT (See Breaking News) I-T - If revenue & profit earned in Philippines is included in Indian Financials and has been offered to tax as per Indian Income Tax Act, no prejudice is caused to revenue so as to invoke Sec 263: ITAT (See Breaking News) TP - Resale Price Method is correctly used for benchmarking where assessee is engaged in pure trading activity, with minimal value addition & where transactions related to purchase & resale are closely interlinked: ITAT (See Breaking News) TP - Management Service Fees received by non-resident firm which constitute pure allocation of cost without any mark-up, being in nature of reimbursement of cost, is not taxable as Royalty: ITAT (See Breaking News) TP - ALP adjustment in respect of corporate guarantee given to AE shall be at 0.5%: ITAT (See Breaking News) I-T - AO shall issue NIL withholding Tax Certificate in respect of cross-cost charges as received by assessee from its AE, if cross charges paid by AE could not be construed as royalty: HC (See Breaking News) I-T- Audit objection does not alter very nature of power to assess/ reassess u/s 147, to power to review concluded assessment : HC (See Breaking News) I-T - TDS provision of section 194C shall not apply on transaction relating to catering service: ITAT (See Breaking News)
 
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TII BREAKING NEWS
 
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, which requires
TP - Benefit test can't be applied for allowability of expenses incurred on intra group services: ITAT
< More News >
 
TII SPECIAL Jun 24, 2024
 
A peep into Global Tax Reforms Architecture
By Pratap Singh, Principal CIT

 

THIS article aims to present an overview of the global tax reforms underway, exploring its challenges, key initiatives, and potential outcomes. It explores the importance of international cooperation under UN/G20/OECD, in addressing tax avoidance and ensuring that businesses contribute their fair share to the societies in which they operate.

 
TII EDIT May 29, 2025
 
The One, Big, Beautiful Bill - A preliminary analysis
By D P Sengupta

FOR Mr. Donald Trump, whatever he does or proposes to do, has to be 'beautiful' and more importantly for him, something that has never been done before in the history of the United States. Following that train of thought, we already have his 'reciprocal tariff' announced on April 2,2025 that has already disrupted

 
BULLETIN BOARD
 
New Delhi, Mar 28, 2025
Order under section 119 of the Income-tax Act, 1961 for waiver on levy of interest under s...
New Delhi, Mar 27, 2025
CBDT amends rules to prescribe new Form 26Q & 27Q...
New Delhi, Mar 25, 2025
CBDT amends rules to expand scope of safe harbour rule ...
New Delhi, Feb 20, 2025
CBDT issues budget circular for TDS u/s 192...
< More News >
 
TII BRIEF
 
Paris, Jun 12, 2025
Germany faces skilled labour paucity: OECD ...
Paris, May 26, 2025
G20 merchandise exports logs 2% growth in Q1 ...
Paris, May 16, 2025
OECD unemployment rate remains stable at 4.9% in March ...
Paris, May 14, 2025
Real household income grew in 2024: OECD ...
Paris, May 13, 2025
Export curbs on critical raw materials sharply rising: OECD ...
 
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