We are pleased to attach herewith the Tax & Regulatory Newsletter – March , 2019 Edition highlighting major recent tax and regulatory developments. Inside this issue…   DIRECT TAX                                                                                                                                                      
  1. Supreme Court holds the year of completion of substantial expansion within a new unit as a fresh “initial assessment year” for claiming 100% deduction of profits
  2. Mumbai ITAT held that the payments received by the foreign company for developing and transferring technical plan does not qualify as FTS in the absence of “make available” condition
  3. Mumbai ITAT held that in the absence of fulfilment of make available condition as mentioned in the India-UK DTAA, no tax is required to be deducted by assessee on payments made to French company
  INTERNATIONAL TAX
  1. France sees global tax deal on digital giants in 2019: Minister
  2. Governments use receipt lotteries to boost tax compliance
  3. EU court issues landmark decision on Member State power to deny tax benefits
  4. Turkey issues guidance on controversial digital tax
  5. Accenture paid £150m to settle Lux Leaks tax dispute
  6. France tries to set trend with internet tax bill
  TRANSFER PRICING
  1. SC dismisses McKinsey India’s SLP; HC upheld its research & information service characterization as KPO
  2. ITAT rules BLT’s inability to provide valid ground for AMP adjustment subsequent to high court’s ruling in prior period; Rejects BEPS actions 8-10 applicability
  3. The HC Upholds ITAT-order treatment of additional interest on AE’s margin-money
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