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...
TDS u/s 195 - for providing standard bandwith services - royalty or business income - The amount received by RJIPL from the assessee for providing standard bandwith services could not be characterised as ‘royalty’ as per the India- Singapore DTAA, and was in fact the “business profits”, which is not taxable as RJIPL did not have any business connection or a PE in India - No TDS
TDS u/s 195 - for providing standard bandwith services - royalty or business income - The amount received by RJIPL from the assessee for providing standard bandwith services could not be characterised as ‘royalty’ as per the India- Singapore DTAA, and was in fact the “business profits”, which is not taxable as RJIPL did not have any business connection or a PE in India - No TDS
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