Mere Subsidiary Relationship Does Not Render Premises of Foreign Counterpart Fixed Place PE in India; ITAT Deletes Rs. 2.41 Crore PE Addition on Donaldson Company Inc September 30, 2026 Read More »
ITAT Cuts BBC India DAPE Profit Attribution from 15% to 12%, Says Enhancement Must Reflect Actual Functions and Risks August 12, 2026 Read More »
HCL Gets ITAT Relief; Foreign Currency Loans Must Be Benchmarked to LIBOR, Not PLR August 4, 2026 Read More »
No Working Capital Adjustment for Delayed Recovery from Debt-Free Branch of Foreign Company; ITAT Allows Rs. 13 Cr Relief To Coca Cola India July 31, 2026 Read More »
ITAT: Salary Paid To Expatriate Employees Deputed To India Is Not ‘Head Office Expenditure’ But Allowable Business Expenditure July 21, 2026 Read More »
ITAT Deletes Transfer Pricing Adjustments Against Vodafone Idea on Brand Royalty, ECB Interest and AMP Expenses July 3, 2026 Read More »
Bombay High Court: Excess Royalty Refunded Under Advance Pricing Agreement Not Taxable in India; GIA India Not A Permanent Establishment of GIA US June 17, 2026 Read More »
Mere Transfer of Skills to Indian Entity Insufficient to Qualify as FTS; Delhi High Court Rejects ‘Make Available’ Argument May 2, 2026 Read More »
ITAT: Voice Termination Service Receipts Not Taxable as Royalty/FTS for Reliance Jio Infocomm Without PE in India April 23, 2026 Read More »
Delhi HC: No Further Income Could Be Attributed To PE In India If Foreign Enterprise Was Remunerated On Arm’s Length Basis December 31, 2025 Read More »
