Exchange of Information under the Multilateral Convention on Mutual Administrative Assistance in Tax Matters with Hong Kong Special Administrative Region of People's Republic of China (Hong Kong SAR) and under the DTAA between India and Hong Kong SAR

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I-T - Subscription-based access to journals, e-magazines or databases is not FTS, unless content is specifically rendered for user's individual requirements: ITAT (See Breaking News)

TP - Revenue-neutral related party payments do not justify transfer pricing adjustment where there is no tax arbitrage: ITAT (See Breaking News)

I-T - Payments made to foreign telecom operators for data transmission services outside India are not royalty under DTAA so as to trigger withholding u/s 195: ITAT (See Breaking News)

TP - Persistent losses in three successive assessment years is sufficient ground for exclusion of comparable: ITAT (See Breaking News)

TP - Failure to first issue a draft assessment order renders final assessment order invalid & without jurisdiction: ITAT (See Breaking News)

I-T - Once established that assessee had sufficient explained foreign income & remittances are duly sourced from such income, consequent investment in immovable property cannot be deemed unexplained merely because certain payments were not fully verifiable at assessment stage: ITAT (See Breaking News)

DTAA - Payment made for offshore supply cannot be construed as FTS in absence of make available clause or no transfer of technology: ITAT (See Breaking News)

TP - Capital contribution to wholly owned subsidiary cannot be re-characterized as loan in absence of debt-like features: ITAT (See Breaking News)

I-T - Internal allocation of expenditure by one branch/head office to another branch of same enterprise cannot be disallowed u/s 40(a)(i) in absence of payment so as to trigger Sec 195: ITAT (See Breaking News)

I-T - Non-obstante clause u/s 144C(13) does not exclude operation of Sec 153 as whole: ITAT (See Breaking News)

Industrial dole-outs reach a new peak since global financial crisis: OECD (See TII Brief)

I-T - Time limit prescribed u/s 153 has to be adhered to and both Section 144C and 153 are mutually inclusive and interdependent: ITAT (See Breaking News)

I-T - Presence of notwithstanding clause in Section 144C(13) would not exclude operation of Section 153: ITAT (See Breaking News)

I-T - Receipts from sale of Renewable Energy Certificates are capital receipts and are not taxable as revenue income: ITAT (See Breaking News)

TP - Section 94B applies only when debt is from non-resident AE and no corresponding restriction exists for resident AE borrowings: ITAT (See Breaking News)

TP - Functional dissimilarity, turnover filter, and abnormal profit calls for exclusion of comparable: ITAT (See Breaking News)

TP - TPO cannot question commercial expediency once expenditure is shown to have been incurred for business purposes; assessee must nevertheless establish that services were indeed rendered: ITAT (See Breaking News)

TP - Comparables selected in previous assessment years need to be included in current year as well, in identical facts & circumstances: ITAT (See Breaking News)

TP - Adjustment on account of interest paid on NCDs cannot be made by ignoring internal CUP: ITAT (See Breaking News)

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Exchange of Information under the Multilateral Convention on Mutual Administrative Assistance in Tax Matters with Hong Kong Special Administrative Region of People's Republic of China (Hong Kong SAR) and under the DTAA between India and Hong Kong SAR By TII News Service Dec 11, 2018 , New Delhi
F.No. 500/43/2018-FT & TR-IV(2)/3166 GOVERNMENT OF INDIA MINISTRY OF FINANCE DEPARTMENT OF REVENUE CENTRAL BOARD OF DIRECT TAXES FT AND TR-IV DIVISION NEW DELHI Dated: December 11, 2018 To, AII Principal Chief Commissioners of Income-tax/ principal Director Generals of Income-tax (Investigation)/ Chief Commissioners of Income tax (Central) Sub: Exchange of Information under the Multilateral Convention on Mutual Administrative Assistance in Tax Matters with Hong Kong Special Administrative Region of People's Republic of China (Hong Kong SAR) and under the DTAA between India and Hong Kong SAR - regarding. The undersigned is directed to convey that the Multilateral Convention on Mutual Administrative Assistance in Tax Matters entered into force for Hong Kong Special Administrative Region (Hong Kong SAR) on 1st September 2018. Further, the Double Taxation Avoidance Agreement between India and Hong Kong SAR (India- Hong Kong SAR DTAA) has entered into force with effect from 30m November 2018. 2. Thus, requests for exchange of information for seeking information in specific cases can be made to Hong Kong SAR under the Multilateral convention on Mutual Administrative Assistance in Tax Matters as well as India- Hong Kong SAR DTAA. 3. The field jurisdictions may furnish requests for exchange of information for seeking information from Hong Kong SAR as per the guidelines laid out in the Manual of Exchange of Information issued by CBDT in May, 2015. 4. This issues with the approval of Chairman, CBDT. (Amrit Agrahari) Under Secretary (FT & TR-IV-I)

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