Loading...

⚠ ✕
❮ Top
☎ Help
☰
×

By creating an account you can:

Logo TaxTMI
Keyword Search :
AI Tools : New
Ask tax questions in natural language. Powered by AI trained on the TaxTMI legal database. Use AI Tools ➞
Call Us / Help / Feedback✕

Contact Us At :

✉ E-mail: [email protected]

✆ Call / WhatsApp at: +91 99117 96707

For more information, Check Contact Us

FAQs :

To know Frequently Asked Questions, Check FAQs

Most Asked Video Tutorials :

For more tutorials, Check Video Tutorials

Submit Feedback/Suggestion :

Email :
Please provide your email address so we can follow up on your feedback.
Category :
Description :
Min 15 characters 0/2000
Make Most of Text Search ✕
  1. Checkout this video tutorial: How to search effectively on TaxTMI.
  2. Put words in double quotes for exact word search, eg: "income tax"
  3. Avoid noise words such as : 'and, of, the, a'
  4. Sort by Relevance to get the most relevant document.
  5. Press Enter to add multiple terms/multiple phrases, and then click on Search to Search.
    6. Text Search
  6. The system will try to fetch results that contains ALL your words.
  7. Once you add keywords, you'll see a new 'Search In' filter that makes your results even more precise.
    8. Text Search
╳
Add to...
You have not created any category. Kindly create one to bookmark this item!
✕
Create New Category
Hide
Title :
Description :
❮❮ Hide
❮ Default View
Expand ❯❯
Close ✕
🔎 Highlights - Adv. Search ❯
TEXT SEARCH:

Press 'Enter' to add multiple search terms. Rules for Better Search

Search In:
Main Text + AI Text ❯
  • Main Text
  • Main Text + AI Text
  • AI Text
Law:
---- All Laws---- ❯
  • ---- All Laws----
  • Income Tax
  • Direct Taxes
  • Benami Property
  • Central GST Laws
  • SGST - State GST Laws
  • Customs
  • FTP - Foreign Trade Policy
  • SEZ - Special Economic Zone
  • FEMA - Foreign Exchange Management
  • Companies Law
  • SEBI - Securities & Exchange Board of India
  • IBC - Insolvency and Bankruptcy
  • Law of Competition
  • PMLA - Money-Laundering
  • Indian Laws
  • Bill / Finance Bills
  • Wealth Tax
  • Service Tax
  • Central Excise
  • VAT / Sales Tax
Month:
---- All Months ---- ❯
  • ---- All Months ----
  • January
  • February
  • March
  • April
  • May
  • June
  • July
  • August
  • September
  • October
  • November
  • December
Year:
---- All Years ---- ❯
  • ---- All Years ----
  • 2026
  • 2025
  • 2024
  • 2023
  • 2022
  • 2021
  • 2020
  • 2019
  • 2018
  • 2017
  • 2016
  • 2015
  • 2014
  • 2013
  • 2012
  • 2011
Sort By: ?
In Sort By 'Default', exact matches for text search are shown at the top, followed by the remaining results in their regular order.
Relevance Default Date
    September 4, 2026   Case Laws SEBI
    Leave to Appeal Against Acquittal: Arguable Points Justify Merits Review, While Certified-Copy Time Is Excluded
    September 4, 2026   Case Laws IBC
    Interim Moratorium Exclusion applies to pending personal-guarantor insolvency proceedings, permitting limited asset-preservation measures pending arbi...
    September 4, 2026   Case Laws IBC
    Section 10A protection bars CIRP where cash-credit and ad hoc facility defaults arise during the protected period.
    September 4, 2026   Case Laws Money Laundering
    PMLA retention safeguards require recorded reasons, evidentiary nexus and fair hearing; non-compliance invalidates continued seizure.
    September 4, 2026   Case Laws Indian Laws
    Assigned secured debts permit banks to use SARFAESI, while borrowers retain merits review of remaining challenges before the Tribunal.
    September 4, 2026   Case Laws Indian Laws
    Codeine cough syrup exemption turns on medicinal dealing, while intoxication diversion triggers NDPS liability and whole-mixture quantification.
    September 3, 2026   Case Laws GST
    Input tax credit fraud permits Section 74 recovery where invoices and payments do not prove receipt of goods.
    September 3, 2026   Case Laws Money Laundering
    PMLA anticipatory bail requires satisfaction of twin conditions, while predicate-offence protection does not extend to independent money-laundering pr...
    September 3, 2026   Notifications Customs
    Sea cargo manifest compliance date is substituted in the Form XII table, effective upon Official Gazette publication.
    September 3, 2026   Circulars DGFT
    Raw sugar tariff-rate quota allocations move to daily batch processing, with pro-rata sharing when remaining quota is exhausted.
    September 3, 2026   Circulars Customs
    Sea cargo manifest electronic filing becomes mandatory through phased port implementation, with no penalties during the transition period.
    September 3, 2026   Circulars GST
    Omission of GST refund restriction rule ends its application to proceedings pending on its omission date.
    September 3, 2026   Case Laws GST
    Security-based bail conditions for alleged tax liabilities were modified when disclosed family assets could secure the alleged dues.
    September 3, 2026   Case Laws GST
    Reasonable cause protects service-tax defaulters from Section 78 penalties when departmental guidance creates genuine interpretational uncertainty.
    September 3, 2026   Case Laws GST
    GST refund restriction omission applies to pending proceedings, requiring related notices, orders and refund claims to be processed accordingly.
    September 3, 2026   Case Laws GST
    Input tax credit for leased construction requires binding precedent consideration; unlawful ledger recovery must be reversed.
    September 3, 2026   Case Laws GST
    Retrospective input tax credit protection overrides delayed-return limits, requiring reconsideration where statutory eligibility under Section 16(5) i...
    September 3, 2026   Case Laws GST
    Electronic gift vouchers can validly pass GST rate-reduction benefits when unconditional, traceable e-wallet credits reach identified customers.
    September 3, 2026   Case Laws GST
    School-affiliation charges remain taxable where not directly connected with examinations, while extended limitation requires proof of deliberate tax e...
    September 3, 2026   Case Laws Income Tax
    Finality of tax liability required before criminal prosecution may be closed; premature closure was set aside for reconsideration.
❮
❯
❯❯
Maximize Maximize Maximize
0 / 200
Expand Note
Add to Folder

No Folders have been created

+

Are you sure you want to delete "My most important" ?

NOTE:

Open Link
Highlights
Showing Results for :
Reset Filters
Results Found:
Show All Summaries Hide All Summaries
September 4, 2026   Case Laws SEBI
Leave to Appeal Against Acquittal: Arguable Points Justify Merits Review, While Certified-Copy Time Is Excluded
September 4, 2026   Case Laws IBC
Interim Moratorium Exclusion applies to pending personal-guarantor insolvency proceedings, permitting limited asset-preservation measures pending arbitration.
September 4, 2026   Case Laws IBC
Section 10A protection bars CIRP where cash-credit and ad hoc facility defaults arise during the protected period.
September 4, 2026   Case Laws Money Laundering
PMLA retention safeguards require recorded reasons, evidentiary nexus and fair hearing; non-compliance invalidates continued seizure.
September 4, 2026   Case Laws Indian Laws
Assigned secured debts permit banks to use SARFAESI, while borrowers retain merits review of remaining challenges before the Tribunal.
September 4, 2026   Case Laws Indian Laws
Codeine cough syrup exemption turns on medicinal dealing, while intoxication diversion triggers NDPS liability and whole-mixture quantification.
September 3, 2026   Case Laws GST
Input tax credit fraud permits Section 74 recovery where invoices and payments do not prove receipt of goods.
September 3, 2026   Case Laws Money Laundering
PMLA anticipatory bail requires satisfaction of twin conditions, while predicate-offence protection does not extend to independent money-laundering proceedings.
September 3, 2026   Notifications Customs
Sea cargo manifest compliance date is substituted in the Form XII table, effective upon Official Gazette publication.
September 3, 2026   Circulars DGFT
Raw sugar tariff-rate quota allocations move to daily batch processing, with pro-rata sharing when remaining quota is exhausted.
September 3, 2026   Circulars Customs
Sea cargo manifest electronic filing becomes mandatory through phased port implementation, with no penalties during the transition period.
September 3, 2026   Circulars GST
Omission of GST refund restriction rule ends its application to proceedings pending on its omission date.
September 3, 2026   Case Laws GST
Security-based bail conditions for alleged tax liabilities were modified when disclosed family assets could secure the alleged dues.
September 3, 2026   Case Laws GST
Reasonable cause protects service-tax defaulters from Section 78 penalties when departmental guidance creates genuine interpretational uncertainty.
September 3, 2026   Case Laws GST
GST refund restriction omission applies to pending proceedings, requiring related notices, orders and refund claims to be processed accordingly.
September 3, 2026   Case Laws GST
Input tax credit for leased construction requires binding precedent consideration; unlawful ledger recovery must be reversed.
September 3, 2026   Case Laws GST
Retrospective input tax credit protection overrides delayed-return limits, requiring reconsideration where statutory eligibility under Section 16(5) is met.
September 3, 2026   Case Laws GST
Electronic gift vouchers can validly pass GST rate-reduction benefits when unconditional, traceable e-wallet credits reach identified customers.
September 3, 2026   Case Laws GST
School-affiliation charges remain taxable where not directly connected with examinations, while extended limitation requires proof of deliberate tax evasion.
September 3, 2026   Case Laws Income Tax
Finality of tax liability required before criminal prosecution may be closed; premature closure was set aside for reconsideration.

Highlights

Back

All Highlights

Showing Results for :
Reset Filters
No Records Found

Highlights

Home › Highlights › Income Tax › 2024 › July, 2024 › This
Back

All Highlights

whatsapp Join Channel
Showing Results for : Reset Filters
Income Tax

Transfer Pricing Adjustment - TPO's reliance on loan data from...

Transfer Pricing Adjustment Overturned Due to Bahrain's Unique Conditions; Withholding Tax on Certifications Justified.

Contents
Summary
Note

Note

-

Bookmark

Print

Print

Print Options

Income Tax July 16, 2024 Case Laws AT
Transfer Pricing Adjustment - TPO's reliance on loan data from the US and Europe for benchmarking is inappropriate given Bahrain's distinct economic environment and sovereign risks. The Prime Lending Rate of Bahrain's Central Bank already incorporates regional factors and risks. Adding spreads for country and forex risks constitutes duplicative adjustments. CUP method necessitates adjustments only if materially impacting price. Assessee's consistent application of interest calculation method underscores reliability. CIT(A)'s order upholding fair benchmarking and appropriate risk adjustments is upheld, dismissing TPO's adjustment. Non-deduction of withholding tax u/s 195 - Product Certification Expenses paid to non-residents do not constitute Fees for Technical Services u/s 9(1)(vii). Services involve evaluating technical quality and issuing certificates, not imparting technical knowledge. Payments to entities in USA, UK, Korea, and China are not taxable in India due to no PE.
View Source View

Topics

Acts Income Tax
Next ➔