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  • International Tax

TPO couldn’t determine ALP of services as Nil without examining docs showing rendition of services by AE

Tenet Tax Daily May 09 2015

Posted onon May 11, 2015
  • Corporate Tax
  • International Tax

AAR couldn’t reject application without explaining how transaction via Mauritius route was made for tax avoidance

Tenet Tax Daily May 08 2015

Posted onon May 11, 2015
  • Corporate Tax

AO can’t make reference to Valuation Officer without declaration of lesser sale price by assessee

Tenet Tax Daily May 07 2015

Posted onon May 11, 2015
  • Corporate Tax

No reassessment after 4 years without obtaining sanction of CIT – original assessment was made under sec. 143(3)

Tenet Tax Daily May 06 2015

Posted onon May 11, 2015
  • Corporate Tax
  • International Tax

No deemed income of NR u/s 9 when it had established Liaison office in India to purchase goods for export

Tenet Tax Daily May 05 2015

Posted onon May 5, 2015
  • Corporate Tax
  • International Tax

Non-resident co.’s service of preparing finance scheme and arranging national and international loans, was ‘consultancy service’

Tenet Tax Daily May 04 2015

Posted onon May 4, 2015
  • Corporate Tax

No sec. 11 relief if trust was doing supermarket business on commercial lines, being not incidental to its objects

Tenet Tax Daily May 01 2015

Posted onon May 1, 2015
  • Corporate Tax

Mere non-registration of asset in name of assessee doesn’t lead to denial of deprecation claim thereon

Tenet Tax Daily April 30 2015

Posted onon May 1, 2015
  • Corporate Tax

No TDS on sum paid for extra cost incurred by contractor due to delay in completion of work by sub-contractor

Tenet Tax Daily April 29 2015

Posted onon May 1, 2015
  • International Tax

No agency PE under India-France DTAA even if agent is wholly dependent on foreign Co. unless transaction isn’t at ALP

Tenet Tax Daily April 28 2015

Posted onon April 28, 2015
  • International Tax

TP adjustment is to be made only in respect of purchases made from AE and not from unrelated parties

Tenet Tax Daily April 27 2015

Posted onon April 28, 2015
  • Corporate Tax

Timely service of sec. 143(2) notice is mandatory and not only a mere procedural requirement

Tenet Tax Daily April 24 2015

Posted onon April 24, 2015
  • Corporate Tax

Penalty leviable if assessee didn’t add back depreciation charged under Companies Act in computation of income

Tenet Tax Daily April 23 2015

Posted onon April 24, 2015
  • Corporate Tax

No disallowance for cash payment for purchase of gold bars held as investment – ITAT

Tenet Tax Daily April 21 2015

Posted onon April 21, 2015
  • Corporate Tax

Assessment order quashed as revenue failed to prove that it was dispatched in time with demand notice

Tenet Tax Daily April 20 2015

Posted onon April 20, 2015
  • Corporate Tax

Sum received towards installation of mobile antenna on terrace was taxable as income from house property

Tenet Tax Daily April 18 2015

Posted onon April 20, 2015
  • Corporate Tax

Usance charges paid to NR on import purchases would be considered as an interest; liable to TDS

Tenet Tax Daily April 17 2015

Posted onon April 17, 2015
  • Corporate Tax
  • International Tax

TP norms would not put fetters on selection of foreign comparables if Indian Cos didn’t satisfy test of comparability

Tenet Tax Daily April 16 2015

Posted onon April 17, 2015

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