Home Highlights February 2019 Year 2019 This

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1. The Income Tax Appellate Tribunal (ITAT) held that the assessee is entitled to the concessional tax rate of 10% on royalty income u/s 115BBF, as the assessee had...

2. The assessee, a foreign company, earned network transportation fees from its Indian associated enterprise (AE), Damco India Private Limited (DIPL). The Assessing Officer...

3. TP Adjustment - Receipt of royalty income from its associated enterprises - when the approach adopted by the assessee is found to be acceptable, the adjustment...

4. TP adjustment - consideration paid to the associated enterprise pursuant to the merger of the holding company (i.e. subsidiary of associated enterprise) with the...

5. Higher rate of tax @60% u/s 115BBE - though the alleged surrendered income is a business income but since assessee being individual having no limitation of earning...

6. TP Adjustment - Addition considering the interest free loan and advances to its Associated Enterprises - As assessee got such huge business from its associated...

7. The assessee had been following the mercantile system of accounting, wherein book profits are taken for tax assessment, though credit or debit amounts may not be...

8. Income accrued in India - Taxability as Royalty income - the income earned by the assessee from sale of software, either directly to the customers in India or through...

9. Addition on account of cash deposit to the bank account of the assessee - assessee is consistently submitting that the assessee has two bank accounts in her name and the...

10. Royalty receipts - income deemed to accrue or arise in India - assessee had sold software licenses to its associated enterprises and to other Indian customers - The ITAT...

11. Income accrued in India - interest income and commitment fees earned by DZ Bank from its Indian clients - PE in India - Once entire interest revenues earned in India in...

12. Transfer pricing officer (TPO) erred by considering non-associated enterprise (non-AE) revenue and costs while computing transfer pricing (TP) adjustment, contrary to...

13. Rate of tax on Interest Income - how the tax rate of non resident companies in their respective countries will be applied on this interest income earned by the assessee...

14. Penalty levied u/s 274 read with Section 270A - assessee computed tax on disallowed depreciation amount at maximum marginal rate and levied 200% penalty on payable tax -...

15. Assessee employed by Indian entity but sent on long-term international assignment to Singapore. Salary received in India for administrative reasons, but employment...