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I-T - Exercising substantial control over day-to-day operations of hotels, going well beyond mere advisory role, thereby qualify Hyatt International as Permanent Establishment: SC (See Breaking News)

I-T - Existence of Permanent Establishment is sufficient to attract tax liability for foreign entity in India, even in absence of exclusive possession of fixed place of business: SC (See Breaking News)

I-T -Temporary or shared use of premises, when combined with administrative or operational control, is adequate to establish PE, thereby triggering income tax liability in India: SC (See Breaking News)

DTAA - Mere availing of services that may require technical expertise would not qualify consideration paid for such services as FTS: HC (See Breaking News)

TP - TPO is not authorized to challenge commercial prudence or benefit derived from services in absence of substantive contrary evidence: ITAT (See Breaking News)

TP - Data under CUP method is not available and data of margins under TNMM is readily available, then it would be appropriate to apply TNMM method as Most Appropriate Method: ITAT (See Breaking News)

I-T - Non-resident bank can claim set off of current year business loss of PE against interest income earned from Indian customers, if treaty itself provides for taxability of income in terms with Income Tax Act: ITAT (See Breaking News)

I-T - Payments made to non-resident entities towards testing services are liable for deduction of tax at source u/s 195, if testing did not involve any transfer of technical knowledge: ITAT (See Breaking News)

INTL -Internal procedural variations or user functionalities within ITBA system cannot override statutory timelines: ITAT (See Breaking News)

INTL - Where no hierarchy for set-off is prescribed under the Act, therefore, assessee is entitled to adopt a beneficial order of set-off of capital losses: ITAT (See Breaking News)

INTL - Corporate guarantee falls within the scope of international transactions under the Act & in keeping with settled precedent, corporate guarantee fee be computed at 0.5%: ITAT (See Breaking News)

I-T - Any legal contention or even claim would be permissible to be raised for first time before appellate authority or Tribunal when facts necessary to examine such contention or claim are already on record: HC (See Breaking News)

I-T - Provisions of DTAA would override provisions of Income Tax Act if provisions of DTAA are more beneficial to assessee: HC (See Breaking News)

DTAA - Receipts for satellite data transmission services do not qualify as royalty either under the Act or DTAA & are not taxable in India in absence of permanent establishment: ITAT (See Breaking News)

DTAA - As per Article 12(4) of India-USA DTAA, for a service to be classified as Fees for Included Services, it must not only be technical or consultancy in nature but also make available technical knowledge, skill, know-how, or processes: ITAT (See Breaking News)

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TII BREAKING NEWS

New Delhi, Jul 25, 2025 By TII News Service

I-T - Exercising substantial control over day-to-day operations of hotels, going well beyond mere advisory role, thereby qualify Hyatt International as Permanent Establishment: SC

New Delhi, Jul 25, 2025 By TII News Service

DTAA - Mere availing of services that may require technical expertise would not qualify consideration paid for such services as FTS: HC

New Delhi, Jul 25, 2025 By TII News Service

TP - TPO is not authorized to challenge commercial prudence or benefit derived from services in absence of substantive contrary evidence: ITAT

Mumbai, Jul 25, 2025 By TII News Service

TP - Data under CUP method is not available and data of margins under TNMM is readily available, then it would be appropriate to apply

< More News >

FROM TII ARCHIVE

Jun 29, 2010

Source State Taxation and India - What the future holds?

By A. J. Majumdar

TAXATION of persons owing economic allegiance to a State is the sovereign right of that State exercisable only within its boundary. The operation of the law can also extend to persons, things and acts outside the State in certain circumstances. Government of India Act, 1935, or Article 245 of the Constitution of Independent India

View Previous Column >>

TII EDIT

Jun 20, 2025

The Revenge Tax of Mr Trump

By D P Sengupta

20th January 2025. Immediately after assuming the office of the US presidency, Mr. Donald Trump, issues a flurry of executive orders and executive notes. One such note is captioned the "America First Trade Policy." Outlined therein are a slew of actions to be taken by the Secretary of the

View Previous Column >>

BULLETIN BOARD

New Delhi, Jul 02, 2025
CBDT notifies 376 as cost inflation index...

New Delhi, Jul 01, 2025
larification regarding CBDT's Circular No. 5/2025 dated 28.03.2025 for waiver on levy of i...

New Delhi, Jun 25, 2025
CBDT notifies Protocol amending India-Oman DTAA ...

New Delhi, Jun 25, 2025
Relaxation of time limit for processing of valid returns of income filed electronically pu...

< More News >

TII BRIEF

Paris, Jul 10, 2025
Netherlands to grow at 1.3% rate in 2025: OECD ...

Paris, Jun 27, 2025
OECD to release Tax Inspectors Without Borders' 10-yr Report ...

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 ...

More News >>

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