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Category: International Tax

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  • International Tax

Loss making company for Transfer Pricing analysis to include companies declaring losses consistently for 3 consecutive AYs

Tenet Tax Daily January 11 2020

Posted onon January 22, 2020
  • International Tax

Benchmarking intra-group services availed by assessee from AE – TNMM most appropriate method

Tenet Tax Daily January 10 2020

Posted onon January 22, 2020
  • International Tax

Profit Split Method adopted without examining expenses incurred by AE vis-à-vis assessee – issue remitted back

Tenet Tax Daily January 09 2020

Posted onon January 22, 2020
  • International Tax

Editing and Proof reading services not FTS and hence not taxable in India

Tenet Tax Daily January 08 2020

Posted onon January 22, 2020
  • International Tax

If salary is considered as part of operating cost, Forex cost mark-up was required while making salary payment to expat employee

Tenet Tax Daily October 16 2019

Posted onon October 31, 2019
  • International Tax

If recipient cannot perform such services on its own, sum received for providing technical services not taxable as FTS

Tenet Tax Daily October 14 2019

Posted onon October 31, 2019
  • International Tax

Payments made to foreign co. towards installation and repair work of wind turbine abroad taxable as FTS in India

Tenet Tax Daily October 08 2019

Posted onon October 31, 2019
  • International Tax

International transactions of payment of FTS to be benchmarked by applying TNMM as most appropriate method

Tenet Tax Daily October 05 2019

Posted onon October 29, 2019
  • International Tax

In case where no PE in India, sum received for supply of equipment and its installation are not taxable as FTS

Tenet Tax Daily September 28 2019

Posted onon September 30, 2019
  • International Tax

If average collection period of outstanding trade receivable is less than industry’s average TP additions are not warranted

Tenet Tax Daily September 27 2019

Posted onon September 30, 2019
  • International Tax

Issue of existence of LG’s PE in India remanded to DRP for examination and decision: ITAT

Tenet Tax Daily September 18 2019

Posted onon September 21, 2019
  • International Tax

Rejection of assessee’s benchmarking of royalty payment by TPO without any basis is unsustainable

Tenet Tax Daily September 17 2019

Posted onon September 21, 2019
  • International Tax

Draft order not required to be issued for rectifying mistakes which happened while giving effect to DRP’s directions

Tenet Tax Daily September 11 2019

Posted onon September 13, 2019
  • International Tax

Arrest warrant issued by TPO without issuing SCN to be quashed:HC

Tenet Tax Daily September 09 2019

Posted onon September 13, 2019
  • International Tax

Computing of ALP on adhoc basis by AO held not justified: ITAT

Tenet Tax Daily August 23 2019

Posted onon August 26, 2019
  • International Tax

No TDS in case of Foreign Company receiving compensation for breach of contract since it did not have a PE in India

Tenet Tax Daily August 16 2019

Posted onon August 19, 2019
  • International Tax

TPO cannot question justification for purchase of Know-how – he can only determine ALP of the purchase

Tenet Tax Daily August 12 2019

Posted onon August 12, 2019
  • International Tax

Payment received by Foreign Company for installation and supervision of pipes and fittings is not FTS

Tenet Tax Daily August 06 2019

Posted onon August 12, 2019

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