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June 27, 2024

ITAT Remanded Matter as CIT(A) Dismissed All Grounds of Appeal Based on a Single Issue

Case Details: Computer Sciences Corporation … Continue reading “ITAT Remanded Matter as CIT(A) Dismissed All Grounds of Appeal Based on a Single Issue”

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June 18, 2024

WDV as Reflected in Books of AE Can’t Be Considered While Computing ALP of Assets Purchased From AE | HC

Case Details: PCIT v. Sarens … Continue reading “WDV as Reflected in Books of AE Can’t Be Considered While Computing ALP of Assets Purchased From AE | HC”

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May 7, 2024

NR Not Eligible to Approach DRP if He Was Declared as Resident by AO During Draft Assessment Proceedings

Case Details: Aldrin Alberto Araujo … Continue reading “NR Not Eligible to Approach DRP if He Was Declared as Resident by AO During Draft Assessment Proceedings”

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May 4, 2024

ITAT Justified Rejection of TNMM Method as TPO Considered Rates as on Invoice Date Instead of Agreement Date

Case Details: Principal Commissioner of … Continue reading “ITAT Justified Rejection of TNMM Method as TPO Considered Rates as on Invoice Date Instead of Agreement Date”

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April 19, 2024

No Need for a Registered/Notarized Agreement for Undertaking International Transactions With Group Cos | ITAT

Case Details: CRM Services India … Continue reading “No Need for a Registered/Notarized Agreement for Undertaking International Transactions With Group Cos | ITAT”

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February 16, 2024

No Legal Bar in Selecting Foreign AE as Tested Party for Determining ALP | HC

Case Details: PCIT v. ITC … Continue reading “No Legal Bar in Selecting Foreign AE as Tested Party for Determining ALP | HC”

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January 9, 2024

[Opinion] All About Form 3CEB by Non-Residents

CA Mohit Manav Sharma & … Continue reading “[Opinion] All About Form 3CEB by Non-Residents”

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January 5, 2024

[Opinion] All about Safe Harbour Rule

CA Mohit Manav Sharma & … Continue reading “[Opinion] All about Safe Harbour Rule”

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December 14, 2023

ALP of Intra-group Services Cannot be Considered Nil If Services Were Backed by Agreement & Evidence | ITAT

Case Details: Pall India (P.) … Continue reading “ALP of Intra-group Services Cannot be Considered Nil If Services Were Backed by Agreement & Evidence | ITAT”

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December 4, 2023

No TP Adjustment If Providing Performance Guarantee or Corporate Guarantee Did Not Give Any Benefit to AE | ITAT

Case Details: Afcons Infrastructure Ltd. … Continue reading “No TP Adjustment If Providing Performance Guarantee or Corporate Guarantee Did Not Give Any Benefit to AE | ITAT”