Transfer pricing and tax deductions upheld on established principles, while employee contributions and warranty provisions returned for fresh examinat...
Captive transfer pricing relies on industrial consumer tariffs, while genuine quotations can benchmark effluent treatment transfers under the Other Me...
Specific tariff classification for ophthalmic instruments and extended limitation principles determine the treatment of duty demands, confiscation, an...
Integrated golf function determines classification, placing launch monitors and simulators under other golf equipment rather than measuring instrument...
Public servant status under anti-corruption law extends to recognised stock exchange leadership; constitutional and sanction challenges do not succeed...
Acquiescence, homebuyer protection and clean-slate resolution principles prevent landowners from disrupting an integrated project through late termina...
Receipts from SaaS-based product analytics services rendered to Indian customers were held not taxable as royalty or as fees for technical services/included services under the Act or the India-USA DTAA, because customers only availed services and did not acquire any right to use the assessee's infrastructure, software, or other assets for commercial exploitation. The Tribunal followed jurisdictional High Court and coordinate bench rulings, including Amazon Web Services, and deleted the addition for both assessment years. On TDS credit, the matter was remitted for verification, with directions to allow due credit and recompute interest and allied relief consequentially to the deletion of the substantive addition.
Receipts from SaaS-based product analytics services rendered to Indian customers were held not taxable as royalty or as fees for technical services/included services under the Act or the India-USA DTAA, because customers only availed services and did not acquire any right to use the assessee's infrastructure, software, or other assets for commercial exploitation. The Tribunal followed jurisdictional High Court and coordinate bench rulings, including Amazon Web Services, and deleted the addition for both assessment years. On TDS credit, the matter was remitted for verification, with directions to allow due credit and recompute interest and allied relief consequentially to the deletion of the substantive addition.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4803
Join Channel
TaxTMI 
