Transfer-pricing comparability permits fresh objections and filters where software service comparables are functionally unsuitable for arm's-length pr...
Territorial rendering requirement excludes China-based management and consultancy services from fees for technical services under the India-China DTAA...
FEMA borrowing restrictions bind charitable trusts, and civil penalties apply without proving intent for delayed repayment of non-resident rupee loans...
Faceless assessment permits Assessment Units to exercise Assessing Officer functions, including issuing scrutiny notices, without requiring the National Faceless Assessment Centre to issue them. ESOP discount reimbursed to a holding company constitutes employee compensation accruing over the vesting period where the liability has arisen and is reasonably estimable; later exercise, lapses or forfeitures require corresponding adjustments. A disallowance for failure to deduct tax from settlement compensation requires an identified statutory withholding obligation. Relinquishment of a right to sue does not itself establish payment for services, commission, brokerage, professional or technical services, or a non-compete arrangement; for non-resident payments, withholding depends on taxability in India.
Faceless assessment permits Assessment Units to exercise Assessing Officer functions, including issuing scrutiny notices, without requiring the National Faceless Assessment Centre to issue them. ESOP discount reimbursed to a holding company constitutes employee compensation accruing over the vesting period where the liability has arisen and is reasonably estimable; later exercise, lapses or forfeitures require corresponding adjustments. A disallowance for failure to deduct tax from settlement compensation requires an identified statutory withholding obligation. Relinquishment of a right to sue does not itself establish payment for services, commission, brokerage, professional or technical services, or a non-compete arrangement; for non-resident payments, withholding depends on taxability in India.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4891 
