Not filing return may trigger notice
Having a PAN and not filing a return may be a strict NO NO. It can trigger assessment notice. In…
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Today's
Wrong reopening ......Read More
Yesterday's In no way the AO has power to question arm’s length pricing in unrelated party transactions ......Read More
Yesterday's In no way the AO has power to question arm’s length pricing in unrelated party transactions ......Read More
Huge stakes plus suspense w.r.t. tds defaults qua non -resident payments
It is sad that there is no specific period of limitation prescribed for ini tiating action in consequence of any…
......Read MoreBack-end operations do not constitute Permanent establishment
Mere back-end operations outfit is held to be excluded from the term “permanent establishment” and classified as one for the…
......Read MoreMost Favoured Nation clause (MFN) in tax treatise is made most difficult to give effect to
In the matter of interpretation of treaties the Supreme Court in their decision in [2021] 432 ITR 471 (SC) held…
......Read MoreOutsourcing/sub-contracting could sense grey area in NR PE factor- IBM case scenario
In an interesting situation IBM India obtained a contract to undertake payroll and data management function for P&G India in…
......Read MoreNotional Provisions are not taxable even if so appearing in 26AS
Only because the other party has made a notional provision in its books and made a deduction of tax and…
......Read MoreUnbecoming of Tribunal
The Kolkata bench of ITAT in [2023] 32 ITR (Trib)-OL 533 (ITAT[Kolk]) held that the income earned from testing services is taxable…
......Read MoreWHETHER ASSESSEE CAN RESILE FROM MOST APPROPRIATE METHOD ADOPTED IN ITS TP REPORT
The transfer pricing report and the most appropriate method adopted by the assessee is not sacrosanct and may require a…
......Read MoreShare application money pending allotment
Before the Tribunal in [2023] 32 ITR (Trib)-OL 253 (ITAT[Mum]) the bench had to decide whether the share application money…
......Read MoreTPO Activism
Vide Case Reference: [2022] 447 ITR 585 (All) the instructions issued by the board u/s 119 need to be implemented…
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