Approved resolution plans extinguish unsubmitted pre-approval tax claims, preventing later recovery outside the insolvency process and preserving a cl...
Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
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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