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Different approach for similar transaction could not be taken for TP analysis...
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Karnataka HC laid down twin tests to establish 'Make Available'...
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Secondment of employees to foreign AE is not HR activity, TP analysis not required...
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Payment made to foreign company to impart distance e-learning education is not royalty...
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TP : Application of Genisy's case in case of assessee who was providing IT support services and R&D services to its AE...
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IT/ILT : Transfer pricing - Selection of comparables for determination of arm's length price without affording opportunity of being heard to assessee...
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IT/ILT: Assessee was to be given a standard deduction of five per cent as provided under proviso to section 92C(2) while computing ALP...
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TP : Extended limitation period available to AO once reference is made to TPO, nonetheless no adjustment is made in ALP...
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Office Memorandum [F.No. 500/54/2012-FTD.I] - Reconstitution of advisory group for international taxation and Transfer Pricing in Department of Revenue, Ministry of Finance
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Press Release - CBDT clarifies "Vodafone was warned"
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PRESS RELEASE - IT/ILT : CBDT clarifies "Vodafone was Warned"
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Order [F. No. 500/15/2011—FT&TR-1] - Section 144C of the Income-tax Act, 1961 - Dispute Resolution Panel - Reference to - Constitution of DRP at specified places - Corrigendum to Order No. 4/FT&TR/2012, dated 10-4-2012
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Order No. 4/FT&TR/2012 [F.No. 500/15/2011-FT&TR-I] - Section 144C of the Income-tax Act, 1961 - Dispute resolution panel - Reference to - Constitution of DRP at specified places - modification of order no. 1/ft&tr/2012 and no. 2/ft&tr 2012
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S. Africa - Luxembourg DTAA - Capital gain to include deemed alienation of property...
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Applying GAAR provisions, US Court treated purchase of shares as loan transaction...
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ILT : Tax Court of Canada of GAAR...
Resolution of International Tax Disputes Under Bilateral Investment Treaties
VIPAN KUMAR
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Retrospective legislative amendments in tax laws, with specific reference to the Supreme Court decision in Vodafone
Vijay Krishnamurthy
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U.S. Tax Developments - April 2012
Charles W. Cope
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UK Tax Update - April 2012
James macLachlan
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International Taxation
Direct Tax Laws
Foreign Cases
Case Laws
[2012] 21 taxmann.com 256 (BANG. - ITAT)
Different approach for similar transaction could not be taken for TP analysis...
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[2012] 21 taxmann.com 214 (KAR.)
Karnataka HC laid down twin tests to establish 'Make Available'...
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[2012] 21 taxmann.com 173 (AHD. - ITAT)
Secondment of employees to foreign AE is not HR activity, TP analysis not required...
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[2012] 21 taxmann.com 171 (DELHI - ITAT)
Payment made to foreign company to impart distance e-learning education is not royalty...
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[2012] 21 taxmann.com 160 (BANG. - ITAT)
TP : Application of Genisy's case in case of assessee who was providing IT support services and R&D services to its AE...
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[2012] 21 taxmann.com 139 (BANG. - ITAT)
IT/ILT : Transfer pricing - Selection of comparables for determination of arm's length price without affording opportunity of being heard to assessee...
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[2012] 21 taxmann.com 137 (BANG. - ITAT)
IT/ILT: Assessee was to be given a standard deduction of five per cent as provided under proviso to section 92C(2) while computing ALP...
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[2012] 21 taxmann.com 145 (CHENNAI - ITAT)
TP : Extended limitation period available to AO once reference is made to TPO, nonetheless no adjustment is made in ALP...
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Statutes
Office Memorandum [F.No. 500/54/2012-FTD.I] - Reconstitution of advisory group for international taxation and Transfer Pricing in Department of Revenue, Ministry of Finance
ReConstitution of ADVISORY GROUP FOR INTERNATIONAL TAXATION AND TRANSFER Pricing in DEPARTMENT OF REVENUE, MINISTRY OF FINANCE Office Memorandum [F.No. 500/54/2012-FTD.I], dated 3-5-2012 In furt...
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Press Release - CBDT clarifies "Vodafone was warned"
CBDT clarifies Vodafone was warned PRESS Release, dated 2-5-2012 A news report has appeared in the Financial Express, Delhi edition, 27th April, 2012 captioned I-T didn 39 t warn Vodafone of tax...
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PRESS RELEASE - IT/ILT : CBDT clarifies "Vodafone was Warned"
CBDT clarifies Vodafone was warned PRESS Release, dated 2-5-2012 A news report has appeared in the Financial Express, Delhi edition, 27th April, 2012 captioned I-T didnt warn Vodafone of ...
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Order [F. No. 500/15/2011—FT&TR-1] - Section 144C of the Income-tax Act, 1961 - Dispute Resolution Panel - Reference to - Constitution of DRP at specified places - Corrigendum to Order No. 4/FT&TR/2012, dated 10-4-2012
Section 144C of the Income-tax Act, 1961 - Dispute Resolution Panel - Reference to - Constitution of DRP at specified places - Corrigendum to Order No. 4/FT 38 TR/2012, dated 10-4-2012 order [F...
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Order No. 4/FT&TR/2012 [F.No. 500/15/2011-FT&TR-I] - Section 144C of the Income-tax Act, 1961 - Dispute resolution panel - Reference to - Constitution of DRP at specified places - modification of order no. 1/ft&tr/2012 and no. 2/ft&tr 2012
Section 144C of the Income-tax Act, 1961 - Dispute resolution panel - Reference to - Constitution of DRP at specified places - modification of order no. 1/fttr/2012 and no. 2/fttr 2012 ORDER N...
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News
Many recommendations on DTC to come into effect in 2013-14: FM
Vodafone-like cases can be reopened in 6-yr window
FM's googly on indirect transfers
Analysis of changes made by Lok Sabha in Finance Bill, 2012
Finance Minister's speech dated 7-5-2012 on Finance Bill, 2012
Case Laws
[2012] 21 taxmann.com 262 (BOM.)
IT : In case of search and seizure, when an amount retained under section 132(5) is found more than amount required to discharge existing liability and total amount of tax plus penalty determined after regular assessment, interest under section 132B(4) is payable on excess amount retained...
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[2012] 21 taxmann.com 288 (MUM. - ITAT)
Shifting from rented to owned premise is extension of business, interest exp. attracts disallowance under sec. 36(1)(iii)...
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[2012] 21 taxmann.com 256 (BANG. - ITAT)
Different approach for similar transaction could not be taken for TP analysis...
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[2012] 21 taxmann.com 267 (BOM.)
Redemption of preference shares, between companies under same management, is not a sham transaction...
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[2012] 21 taxmann.com 255 (SC)
Levy of Stamp Duty on Power of Attorney given to unrelated person is constitutionally valid - Supreme Court...
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[2012] 21 taxmann.com 254 (CHD. - ITAT)
IT Inspector not authorized to take statement in survey, if taken it wouldn't have any evidentiary value...
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[2012] 20 taxmann.com 655 (KER.)
IT : Credit of tax based on TDS certificates be allowed in respect of interest income in the year in which subject-matter of deduction of tax is assessed...
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[2012] 20 taxmann.com 171 (KAR.)
IT: Expenditure incurred towards communications expenses as well as travelling, boarding and conveyance expenses is to be reduced from total turnover while computing deductions under section 10A...
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Statutes
ORDER [NO. F-46-AD(AT)2012] - IT : Cancellation of Transfer Order of Judicial Member, Chandigarh Benches to Pune Benches of ITAT
Cancellation of transfer order of Judicial Member, Chandigarh Benches to Pune Benches of ITAT ORDER [NO. F-46-AD(AT)2012], DATED 14-5-2012 In partial modification of this office order of ...
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17/2012 - IT : Notified undertaking under section 80-IA of the Income-tax Act, 1961
Section 80-IA of the Income-tax Act, 1961 - Deductions - Profits and gains from industrial infrastructure undertakings, etc. - Notified undertakings Notification No. 17/2012 [F.No. 178/38/2...
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ORDER [NO. F-46-AD(AT)2012] - IT : Transfer of Specified Members of ITAT from One Bench(es) to Another Bench(es)
Transfer of specified members of ITAT from one Bench(es) to another Bench(es) ORDER [NO. F-46-AD(AT)2012], DATED 11-5-2012 In pursuance of the consultations of the collegium of the Income...
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NC-32/2012 [S.O. 1030(E)] - IT : Notified Eligible Projects or Schemes under section 35AC
Section 35AC, read with Explanation (b) thereto of the Income-tax Act, 1961 - Eligible projects or schemes, expenditure on - Notified eligible projects or schemes Notification No. 32/2012 [...
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Office Memorandum [F.No. 500/54/2012-FTD.I] - Reconstitution of advisory group for international taxation and Transfer Pricing in Department of Revenue, Ministry of Finance
ReConstitution of ADVISORY GROUP FOR INTERNATIONAL TAXATION AND TRANSFER Pricing in DEPARTMENT OF REVENUE, MINISTRY OF FINANCE Office Memorandum [F.No. 500/54/2012-FTD.I], dated 3-5-2012 In furt...
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News
LIC hikes stake in Bank of Maharashtra
PE’s & VCs eye exit via offer for sale after STT ruling
GST: States to bargain hard with individual rates
No-frill a/c’s on mobile
RBI digs deep but rupee sinks further
FM Promises Austerity Round II to Fix Mess
Trai Proposals to Hit Axiatas Idea Fundings
Case Laws
[2012] 21 taxmann.com 253 (SCA - South Africa)
S. Africa - Luxembourg DTAA - Capital gain to include deemed alienation of property...
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[2012] 21 taxmann.com 252 (TC - US)
Applying GAAR provisions, US Court treated purchase of shares as loan transaction...
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[2012] 21 taxmann.com 70 (TC - CANADA)
ILT : Tax Court of Canada of GAAR...
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[2012] 21 taxmann.com 16 (FC - AUSTRALIA)
ILT:Federal Court of Australia on GAAR...
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[2012] 20 taxmann.com 573 (CA - US)
ILT : US fourth Circuit Court of Appeal on GAAR...
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[2012] 20 taxmann.com 523 (FC - AUSTRALIA)
ILT : Australian Court unmasks - Tax avoidance scheme relating to payment of bonus to MD/CEO...
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[2012] 20 taxmann.com 413 (CC - UK)
ILT : UK Upper Tribunal Tax and Chancery Chamber on elimination of double taxation under article 23 of DTAA between UK and US...
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[2012] 20 taxmann.com 414 (TC - CANADA)
ILT : If there are both tax and non-tax purposes to a transaction, it must be determined whether it is reasonable to conclude that non-tax purpose is primary; if so, GAAR cannot be applied to deny tax benefit...
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