Transfer-pricing treatment of ITeS margins excludes pass-through tax recoveries and separate delayed-receivables interest after working-capital adjust...
Capacity-utilisation adjustments under TNMM can neutralise substantiated COVID-related idle costs where underutilisation materially affects profitabil...
TNMM functional comparability requires excluding rice manufacturers from a pure Basmati rice trader's benchmark and recognising operating export recei...
Working-capital adjustment subsumes delayed-receivable effects in TNMM benchmarking of captive software-development services, avoiding separate notion...
Transfer-pricing comparability requires exclusion of financially illogical super-profit comparables and correction of unsupported annual-report and ma...
Charitable character assessment preserves Section 80G approval despite inclusive spiritual teachings and incidental religious expenditure within the s...
Penalty proceedings for cash-loan acceptance require assessment proceedings and recorded Assessing Officer satisfaction; absent these, the proceedings...
Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-ca...
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Live broadcasting rights, characterised as a one-time transmission without an enduring benefit, are neither a scientific work nor rights in which copyright subsists. Licence fees for those rights therefore fall outside royalty treatment under the India-UK DTAA, unlike non-live repeat telecasts and highlights. A mutually agreed allocation of broadcasting fees between live and non-live rights remains valid absent material showing that the allocation is unjustified. Release fees received for permitting athletes to participate in a league, being separate from player remuneration and not arising from athletes' personal activities, fall outside the athlete-income provision of the India-UK DTAA.
Live broadcasting rights, characterised as a one-time transmission without an enduring benefit, are neither a scientific work nor rights in which copyright subsists. Licence fees for those rights therefore fall outside royalty treatment under the India-UK DTAA, unlike non-live repeat telecasts and highlights. A mutually agreed allocation of broadcasting fees between live and non-live rights remains valid absent material showing that the allocation is unjustified. Release fees received for permitting athletes to participate in a league, being separate from player remuneration and not arising from athletes' personal activities, fall outside the athlete-income provision of the India-UK DTAA.
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