Pre-existing disputes over outcome-based professional fees can bar Section 9 insolvency proceedings where contractual entitlement requires investigati...
Corresponding scheduled offences preserve money-laundering jurisdiction despite repeal of the central corruption provision where conduct remains cover...
Concurrent anticipatory-bail jurisdiction permits applications before either forum, while secured evidence may negate custodial interrogation in GST e...
Page of 4881
Press 'Enter' after typing page number.
621 to 640 of 97618 Results
❮
❯
❯❯
0 / 200
Expand Note
Add to Folder
No Folders have been created
+
Are you sure you want to delete "My most important" ?
Software sub-licensing was treated as provision of services...
Transfer-pricing tolerance for software sub-licensing falls within the services range, eliminating the adjustment and requiring TDS-credit verification.
Contents
Summary
Note
Bookmark
Share
✓ Copied successfully !
Print
Print Options
For full text, please login
Login to TaxTMI
Verification Pending
The Email Id has not been verified. Click on the link we have sent on
Software sub-licensing was treated as provision of services rather than wholesale trading for transfer-pricing tolerance purposes. With four comparable companies in the final dataset, Rule 10CA(7) applied, and the one per cent variation reserved for wholesale trading did not apply because the activity neither involved goods trading nor met inventory conditions. The difference between the arm's length price and transaction price fell within the applicable three per cent range, so the transfer-pricing adjustment was deleted and benchmarking and comparable challenges required no decision. Claimed TDS short credit requires record verification and allowance in accordance with law.
Software sub-licensing was treated as provision of services rather than wholesale trading for transfer-pricing tolerance purposes. With four comparable companies in the final dataset, Rule 10CA(7) applied, and the one per cent variation reserved for wholesale trading did not apply because the activity neither involved goods trading nor met inventory conditions. The difference between the arm's length price and transaction price fell within the applicable three per cent range, so the transfer-pricing adjustment was deleted and benchmarking and comparable challenges required no decision. Claimed TDS short credit requires record verification and allowance in accordance with law.
Note: It is a system-generated summary and is for quick reference only.