Tenet Tax Daily February 05 2015
No addition on basis of remand report by AO if he failed to verify authenticity of facts on merits
TP norms would not put fetters on selection of foreign comparables if Indian Cos didn’t satisfy test of comparability
Tenet Tax Daily February 04 2015
ALP of advertisement exp. reimbursed to foreign AE couldn’t be taken at nil if it was incurred for Indian affiliate
Tenet Tax Daily February 03 2015
HC grants Sec. 80-IA relief on gains attributable to captive consumption of power generated from windmill
Tenet Tax Daily February 02 2015
No TDS credit available if assessee had failed to offer corresponding income to tax in relevant year
Tenet Tax Daily January 31 2015
Wheeling charges paid for transmission of electricity would attract TDS under sec. 194C instead of sec. 194J
Tenet Tax Daily January 28 2015
Brokerage paid to mobilize public deposit was revenue exp. if interest was payable on it and deposit had fixed term
Tenet Tax Daily January 29 2015
Mere mentioning of country’s name and detail of expenses does not indicate purpose of foreign travel; disallowable
Tenet Tax Daily January 30 2015
“Umbrella” of combined entity level TNMM can’t be used to benchmark separate transactions on combined basis
Tenet Tax Daily January 27 2015
ITAT invokes MFN clause to import make available clause from India-Portugese DTAA into the India-Sweden DTAA
Tenet Tax Daily January 26 2015
Manufacturer of printer’s toners couldn’t be a comparable for co. engaged in manufacturing of printing inks
Tenet Tax Daily January 24 2015
Payment made to put-up hoarding is an advertisement contract; attracts TDS under sec. 194C
Tenet Tax Daily January 21 2015
Income from growing of mushrooms in residential area under controlled conditions isn’t agricultural income
Tenet Tax Daily January 20 2015
Sum paid for obtaining permanent right to use design engineering services won’t fall within the purview of royalty
Tenet Tax Daily January 19 2015
Compensation awarded under Motor Vehicle Act and interest accrued thereon in bank weren’t taxable
Tenet Tax Daily January 17 2015
Forex loss couldn’t be considered while computing ALP of purchases if sale/purchase wasn’t at pre-determined rates
Tenet Tax Daily January 16 2015
Share application money paid to AE couldn’t be held as international transaction by deeming it as lending/borrowing
Tenet Tax Daily January 15 2015