Transfer pricing comparables and operating income principles applied to software development services, with exclusions, inclusions, and tax credit ver...
Transfer pricing on performance guarantees and overdue receivables deleted where warranty obligations were embedded and working capital adjustment alr...
Compensation received on termination of network participation agreement from Citibank - Income deemed to accrue or arise in India - received does not fit into any of the definition of royalty either under IT Act or as per DTAA - it falls u/s.28(va)(b) as the business receipt and As per Article 7 of Indo-US DTAA, same is taxable only in USA and not in India - matter however, remanded to inquire for existence of PE in India
Compensation received on termination of network participation agreement from Citibank - Income deemed to accrue or arise in India - received does not fit into any of the definition of royalty either under IT Act or as per DTAA - it falls u/s.28(va)(b) as the business receipt and As per Article 7 of Indo-US DTAA, same is taxable only in USA and not in India - matter however, remanded to inquire for existence of PE in India
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