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Category: International Tax

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Delhi HC examines test of “related party” for deciding maintainability of application before SetCom

Tenet Tax Daily November 17 2015

Posted onon November 18, 2015
  • Corporate Tax
  • International Tax

Reassessment made to tax royalty by invoking ‘Force of Attraction Rule’ quashed by Delhi HC

Tenet Tax Daily November 16 2015

Posted onon November 18, 2015
  • Corporate Tax
  • International Tax

ITAT apportions exp. on living Germplasm and technical know-how between capital and revenue exp.

Tenet Tax Daily November 14 2015

Posted onon November 14, 2015
  • Corporate Tax
  • International Tax

Default period of assessee-in-default shall be counted as per British Calendar month

Tenet Tax Daily November 12 2015

Posted onon November 14, 2015
  • International Tax

Corporate guarantee given to AE by charging 0.5% as service fee doesn’t call for TP adjustment

Tenet Tax Daily November 11 2015

Posted onon November 14, 2015
  • International Tax

Freight to C&F agent wasn’t reimbursement and liable to TDS as agent didn’t made TDS while making payment to Airlines

Tenet Tax Daily November 10 2015

Posted onon November 14, 2015
  • International Tax

Commission paid to NR for advising on product trend in USA isn’t taxable as services were rendered outside India

Tenet Tax Daily November 09 2015

Posted onon November 14, 2015November 14, 2015
  • Corporate Tax
  • International Tax

No incurrence of exp. on services provided by assessee proved that it had outsourced services to AE; No. TP adjustment

Tenet Tax Daily November 06 2015

Posted onon November 14, 2015
  • International Tax

TP: Assessment order set aside as AO made final assessment without forwarding copy of draft assessment order

Tenet Tax Daily November 03 2015

Posted onon November 14, 2015
  • Corporate Tax
  • International Tax

Fee paid for conducting market research & advising on new technological developments in China is FTS

Tenet Tax Daily October 24 2015

Posted onon October 24, 2015
  • Corporate Tax
  • International Tax

Payer not at fault for not approaching AO under sec. 195(2) as it made purchase contract and not composite contract

Tenet Tax Daily October 20 2015

Posted onon October 20, 2015
  • Corporate Tax
  • International Tax

Corporate guarantee given to foreign AE couldn’t be held as international transaction under transfer pricing

Tenet Tax Daily October 17 2015

Posted onon October 20, 2015
  • Corporate Tax
  • International Tax

Prior to 1-6-2013 developer wasn’t liable to TDS on purchase of property from NR due to non-discrimination clause

Tenet Tax Daily October 16 2015

Posted onon October 20, 2015
  • Corporate Tax
  • International Tax

Sum paid for live coverage of IPL matches isn’t FTS under India-UK DTAA

Tenet Tax Daily October 10 2015

Posted onon October 10, 2015
  • Corporate Tax
  • International Tax

Transactions of unlisted shares of group concern at throw away prices wasn’t genuine transactions

Tenet Tax Daily October 09 2015

Posted onon October 10, 2015
  • Corporate Tax
  • International Tax

No disallowance of interest if borrowed sum was given to affiliate without any interest for commercial expediency

Tenet Tax Daily October 07 2015

Posted onon October 7, 2015
  • Corporate Tax
  • International Tax

Delhi ITAT uses ‘Berry Ratio’ to determine ALP for Sogo Sasha entity by following case of ‘Mitsubishi’

Tenet Tax Daily October 06 2015

Posted onon October 7, 2015
  • Corporate Tax
  • International Tax

Provision made by Telecom operator for dismantling towers after termination of lease wasn’t liable to TDS

Tenet Tax Daily October 02 2015

Posted onon October 7, 2015

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