Transfer pricing comparability under TNMM: foreign exchange loss on ECB excluded from operating cost, and a functionally dissimilar comparator removed...
Rate of tax on Royalty / License fee - 10% u/s 115A or higher rate @ 15% as per DTAA with United Kingdom - The provisions of section 115A(1)(b)(AA) does not debar the assessee to enter into new agreements after change of situation - AT
Rate of tax on Royalty / License fee - 10% u/s 115A or higher rate @ 15% as per DTAA with United Kingdom - The provisions of section 115A(1)(b)(AA) does not debar the assessee to enter into new agreements after change of situation - AT
Note: It is a system-generated summary and is for quick reference only.