Pharmaceutical promotion and transfer-pricing comparability principles limited disallowances, while uncorroborated search allegations and unsupported ...
Business expenditure substantiation supports scrap credits, statutory payments and expense claims, while depreciation requires proof of actual busines...
Credit rating and annual surveillance receipts were held not taxable as fees for technical services under the India-Singapore DTAA because the determinative test was whether technical know-how, skill, technology or process had been made available to the client. The Tribunal found that clients received only the rating output, not the underlying expertise or technology used to produce it, and no know-how was transferred. The addition was therefore deleted.
Credit rating and annual surveillance receipts were held not taxable as fees for technical services under the India-Singapore DTAA because the determinative test was whether technical know-how, skill, technology or process had been made available to the client. The Tribunal found that clients received only the rating output, not the underlying expertise or technology used to produce it, and no know-how was transferred. The addition was therefore deleted.
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