Business expenditure deduction requires proof of genuine commission payments and commercial allowability; turnover growth alone cannot validate the cl...
Article 8 treaty coverage excluded third-party airline support services, while documented demonetisation cash receipts remained accepted business inco...
Functional comparability under TNMM requires highway contract benchmarks to reflect operation, maintenance and transfer activities, requiring fresh be...
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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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