Sec. 260A – SLP granted against HC Order that where assessment was initiated at New Delhi and final assessment was framed by AO at Ghaziabad, High Court of Punjab & Haryana lacked jurisdiction to adjudicate matter.
Principal Commissioner of Income-tax v. ABC Paper Mills Ltd. – [2022] 139 taxmann.com 313 (SC).
AMP expenses – Where operating margin earned by assessee in trading segment was at arm’s length, incurring of AMP expenses could not be treated as international transaction.
Lenovo (India) (P.) Ltd. v. Deputy Commissioner of Income-tax – [2022] 139 taxmann.com 340 (Bangalore-Trib.).
CBDT keeps tolerance limit under Transfer Pricing for A.Y.: 2022-23 unchanged.
Notification No. 70/2022, dated 28-06-2022.
DRP has no power to entertain rectification application filed by TPO.
Shapoorji Pallonji Bumi Armada (P.) Ltd. v. ACIT – [2022] 139 taxmann.com 572 (Mumbai-Trib.).
It is not ‘impermissible discrimination’ if higher tax rates are charged to Korean Co. which has not made ‘prescribed arrangements’ u/s 2(22A).
Shinhan Bank v. Deputy Director of Income-tax (International Taxation), [2022] 139 taxmann.com 563 (Mumbai-Trib.).
CBDT issues guidelines for TDS u/s 194S where VDAs are transferred other than through Exchange.
Circular No. 14/2022, dated 28-06-2022.