Building-plan sanction charges require statutory authority; unauthorised fees and GST were quashed, while labour cess must follow prescribed collectio...
Pure-agent exclusion fails where hotel booking facilitators receive third-party services themselves, making entire customer consideration taxable as r...
Transfer pricing requires evidence for AMP transactions, functionally reliable comparables, and appropriate aggregation or Berry Ratio benchmarking me...
Revisionary jurisdiction cannot reopen share capital assessments where adequate inquiry supports a permissible view and no independent error is establ...
Reassessment jurisdiction fails where unverified portal information is aggregated without examining the taxpayer's explanation or relevance of entries...
Statutory sanction for delayed reassessment requires approval from the prescribed authority; approval by an inferior authority invalidates jurisdictio...
Transfer pricing margin adjustments require matching treatment of non-operating income and related costs, with comparability issues reconsidered on ev...
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Payments for onsite software development services routed through a US branch were treated as fees for technical services under domestic law, but treaty relief under the India-US DTAA applied because the make available condition was not satisfied, so no tax was deductible and the section 40(a)(i) disallowance failed. Licensed access to website content carrying the foreign supplier's branding was characterised as royalty, so the non-deduction of tax attracted disallowance. The section 14A/Rule 8D addition was deleted for lack of objective satisfaction, CSR donations remained eligible for deduction under section 80G subject to verification, and the Tangent International issue was remanded for examination of the scope of work.
Payments for onsite software development services routed through a US branch were treated as fees for technical services under domestic law, but treaty relief under the India-US DTAA applied because the make available condition was not satisfied, so no tax was deductible and the section 40(a)(i) disallowance failed. Licensed access to website content carrying the foreign supplier's branding was characterised as royalty, so the non-deduction of tax attracted disallowance. The section 14A/Rule 8D addition was deleted for lack of objective satisfaction, CSR donations remained eligible for deduction under section 80G subject to verification, and the Tangent International issue was remanded for examination of the scope of work.
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