#Section 270A
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746 articlesIncome Tax

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TP on Captive Software Services – Dissimilar Giants Excluded, Adjustment Removed
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Intra-Group Services Allowed as Genuine – ALP Review Sent Back to TPO
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AMP Intensity & BLT Methods Rejected Again; ITAT Deletes Entire AMP Adjustment – Issues Remanded
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Penalty u/s 271AAC & 270A Remanded as Quantum Appeal Restored for Fresh Hearing
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Survey Statement Alone Cannot Sustain Addition Without Stock Verification: ITAT Kolkata
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Assessment Order Void When Issued to Non-Existent Merged Entity: ITAT Mumbai
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ITAT Delhi Deletes ₹68 Cr TP Adjustments: Projections Cannot Be Replaced with Actuals
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Unsecured loan addition deleted since identity, creditworthiness and genuineness proved
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Singapore entity not conduit, satisfies PPT test; Grants LTCG exemption: ITAT Mumbai
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Copyright vs Copyrighted Article – Online Access Not Royalty: ITAT Delhi
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Vague Penalty Notices Without Specified Limb Are Invalid in Law: ITAT Delhi
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Income from Film Distribution was not ‘Royalty’ under India-US DTAA
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DTAA Benefit Granted on LTCG and Dividends to Cyprus-based company
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