Greetings! We are pleased to attach herewith the Tax & Regulatory Newsletter – April, 2019 Edition highlighting major recent tax and regulatory developments. Inside this issue… DIRECT TAX Grouting not ‘construction’, taxpayer constitutes Fixed Place PE Management services taxable as business profit in absence of FTS clause Delhi ITAT holds that CIT(A) can’t impose Rule 11UA when taxpayer ‘substantiated’ higher valuation u/s. 56(2)(viib) before assessing Officer INTERNATIONAL TAX Governments use receipt lotteries to boost tax compliance Ukraine ratifies MLI to amend tax treaties Switzerland Introduces New Tax Rule for Systemically Important Banks France tries to set trend with internet tax bill Australia embraces international co-operation to solve tax challenges posed by the digitalized economy Georgia ratifies tax instrument to tackle BEPS Taiwan Plans Extension of Tax Incentives for R&D Expenses TRANSFER PRICING Application of Transfer Pricing provisions not against “non-discrimination” clause of DTAA; DCF valuation subsumes goodwill HC Accepts “headcount method” as a basis for apportionment of un-allocable cost Company cannot be rejected as a comparable merely on following different-FY wherein the data can be collated from the public domain relating to the year under consideration REGULATORY Recent amendment in Companies (Incorporation) Rules Issue of Master Direction on External Commercial Borrowings and Trade Credits by RBI Nangia & Co LLP_Newsletter_ April , 2019 Edition