Revenue neutrality in domestic related-party loans can require deletion of interest transfer pricing adjustments after domestic-transaction verificati...
Pre-enactment land-sale agreements escape stamp-duty value substitution where substantial banking-channel consideration was received before Section 43...
Finance Act 2025 amendment rendered the challenge to the validity of the assessment infructuous. On taxability of receipts under the India-UK DTAA, the Tribunal held that general business support services rendered under a cost contribution agreement were managerial in nature and did not make available technical knowledge, experience, skill or know-how to the Indian recipient; the receipts were therefore not fees for technical services. It also directed recomputation of interest for the relief granted in appeal.
Finance Act 2025 amendment rendered the challenge to the validity of the assessment infructuous. On taxability of receipts under the India-UK DTAA, the Tribunal held that general business support services rendered under a cost contribution agreement were managerial in nature and did not make available technical knowledge, experience, skill or know-how to the Indian recipient; the receipts were therefore not fees for technical services. It also directed recomputation of interest for the relief granted in appeal.
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