Transfer pricing comparables and adjustments: Tribunal revisits loss-maker status, segmental comparability, working capital relief, and risk allocatio...
Business expenditure disallowance failed where commission, related-party salary and promotion payments were supported by records and inquiry was inade...
TDS u/s 195 - copyrighted software products - payment made by the assessee to its parent company for purchase of copyrighted software to be distributed in India for end users cannot be considered as royalty as defined u/s 9(1)(vi) consequently, the assessee is not required to deduct TDS u/s 195 - hence, no disallowance u/s 40(a)(ia)
TDS u/s 195 - copyrighted software products - payment made by the assessee to its parent company for purchase of copyrighted software to be distributed in India for end users cannot be considered as royalty as defined u/s 9(1)(vi) consequently, the assessee is not required to deduct TDS u/s 195 - hence, no disallowance u/s 40(a)(ia)
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