Patent-settlement expenditure treated as commercially expedient revenue outlay, with foreign-law restrictions inapplicable before the prospective amen...
International transaction benchmarking restricts transfer pricing adjustments to associated-enterprise dealings, while functional comparability govern...
Joint development agreements defer taxable transfer where possession lacks part performance, while completed flats determine consideration and exempti...
Receipts on account of “Sale of Software” - chargeability to tax as income from Royalty u/s 9(1)(vi) and Article 12 of the DTAA - India-Ireland DTAA - Since treaty provisions are more beneficial, an adjudication on nature of receipts vis a vis provisions of Section 9(1)(vi) is not required.
Receipts on account of “Sale of Software” - chargeability to tax as income from Royalty u/s 9(1)(vi) and Article 12 of the DTAA - India-Ireland DTAA - Since treaty provisions are more beneficial, an adjudication on nature of receipts vis a vis provisions of Section 9(1)(vi) is not required.
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