Transfer pricing and tax deductions upheld on established principles, while employee contributions and warranty provisions returned for fresh examinat...
Captive transfer pricing relies on industrial consumer tariffs, while genuine quotations can benchmark effluent treatment transfers under the Other Me...
Specific tariff classification for ophthalmic instruments and extended limitation principles determine the treatment of duty demands, confiscation, an...
Integrated golf function determines classification, placing launch monitors and simulators under other golf equipment rather than measuring instrument...
Public servant status under anti-corruption law extends to recognised stock exchange leadership; constitutional and sanction challenges do not succeed...
Acquiescence, homebuyer protection and clean-slate resolution principles prevent landowners from disrupting an integrated project through late termina...
Under the India-Netherlands DTAA, executive search services that are separate from a licensing arrangement and do not make available technical knowledge, skill, know-how or processes are addressed as neither fees for technical services nor royalty. The note also distinguishes managerial services from treaty-defined technical services, while requiring examination of the specific services under a shared-services agreement. Reimbursements of actual expenses without a profit element are treated separately from fees for technical services. Interest on income-tax refunds is subject to the treaty interest provision, and tax on treaty-covered income cannot exceed the treaty-prescribed rate, including through surcharge and cess. Tax deducted at source credit remains subject to factual verification.
Under the India-Netherlands DTAA, executive search services that are separate from a licensing arrangement and do not make available technical knowledge, skill, know-how or processes are addressed as neither fees for technical services nor royalty. The note also distinguishes managerial services from treaty-defined technical services, while requiring examination of the specific services under a shared-services agreement. Reimbursements of actual expenses without a profit element are treated separately from fees for technical services. Interest on income-tax refunds is subject to the treaty interest provision, and tax on treaty-covered income cannot exceed the treaty-prescribed rate, including through surcharge and cess. Tax deducted at source credit remains subject to factual verification.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4811 
Join Channel 
