Business expenditure substantiation supports scrap credits, statutory payments and expense claims, while depreciation requires proof of actual busines...
Captive power transfer pricing and non-resident export commission rules support deletion of adjustments and withholding disallowance in discussed proc...
Page of 4782
Press 'Enter' after typing page number.
401 to 420 of 95636 Results
❮
❯
❯❯
0 / 200
Expand Note
Add to Folder
No Folders have been created
+
Are you sure you want to delete "My most important" ?
Receipts from seconded employees were held taxable as fees for included services under Article 12 of the India-USA DTAA because the secondees retained their lien with the overseas employer, the Indian entities could only end the assignment, and the services involved training, implementation of group policies, and transfer of technical knowledge, satisfying the make available test. The absence of markup and the label of reimbursement did not change the true character of the arrangement. On the separate issue of services rendered in and from the USA, the Tribunal had not properly examined the nature of the retained receipts or the Assessing Officer's findings, so the matter was set aside and remanded for fresh, reasoned consideration.
Receipts from seconded employees were held taxable as fees for included services under Article 12 of the India-USA DTAA because the secondees retained their lien with the overseas employer, the Indian entities could only end the assignment, and the services involved training, implementation of group policies, and transfer of technical knowledge, satisfying the make available test. The absence of markup and the label of reimbursement did not change the true character of the arrangement. On the separate issue of services rendered in and from the USA, the Tribunal had not properly examined the nature of the retained receipts or the Assessing Officer's findings, so the matter was set aside and remanded for fresh, reasoned consideration.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4782
Join Channel
TaxTMI 
