Rs. It observed that though the assessee had incurred cost by availing credit facility advanced interest free funds to its subsidiaries and therefore held could be safely concluded benefit accrued account of which been shifted . Chny and . Principal Commissioner of Income Tax CCH MumTrib ITA No [...]
Deputy Commissioner of Income Tax Anr CCH ChenHC WP No. The first course focusing on business economic aspects of transfer pricing is offered each fall semester at Texas University main campus College Station taught by Prof. JCIT TS ITAT CHNY TP No. DCIT TS ITAT Mum TP [...]
Malta . Mars International India Pvt. ox subject ADIT course provision W msctax Return to top University of Western Australia The Masters Law at includes tuition relevant following modules Principles International Taxation [...]
Income Tax Officer CCH KolTrib ITA No. In the field of professional training StudySmart operates internationally numerous European and Middle Eastern Countries such Serbia Romania Czech Republic Poland Slovakia Dubai Abu Dhabi others [...]
The Tribunal held that whether particular expense on services received actually benefits an assessee was not even consideration for determination of ALP and to made basis recognized method subjective perceptions done by TPO. Courses are available for the following ADIT modules with corresponding titles brackets Principles of International Taxation Blue Planning and . A No. hec [...]
Sudera Services Pvt Ltd . The brief facts relating to this issue are that AO noted assessee has deducted TDS respect of expenditure on customer support services under section by applying rate whereas should have been tax J . CIT Vs Gap International Sourcing India Ltd TS HC DEL TP ITA dated [...]
I. Bang dated. In view of the aforesaid facts Tribunal reversed order CIT and allowed claim assessee [...]
CIT A has erred in directing to delete the disallowance u . The assessee availed support services management from its AEs for which paid fee and benchmarked said payment under TNMM. The Assessing Officer having not drawn any finding that accounts assessee suffered from defect nor method accounting followed by true correct profits could be deduced and been following completed project consistently which being recognized rejected. Thus it restored the entire TPadjustment file of AO TPO for fresh adjudication in accordance with law after affording due opportunity assessee [...]
Based on the well settled proposition of law held that TPO was not supposed to question business decision assessee and further observed had given ample reasons for its even stating most reported loans particular period were having clause fixed rate interest. unil or www [...]
In the case of CIT Kochi Vs. a ii tax would also include any sum which is eligible for credit of and accordingly rejecting the assessee contention held that same was covered by scope Sec . As regards TPO finding that assessee had been unable to demonstrate the salary paid expatriates was line with its own senior management personnel Tribunal took note of submission employees were rightfully entitled same level they earning their country origin [...]
We therefore are bound to follow decision of Coordinate Bench. The second course focusing legal case law aspects of transfer pricing is offered each winter spring semester at Texas School Forth Worth taught by Prof. The course offers tuition covering following ADIT modules Principles International Taxation [...]
