Restricted silver imports may clear under a valid import authorisation without additional status or exchange-routing requirements unless expressly imp...
Head Office cost allocation requires prescribed transfer-pricing methods; treaty ceilings bar surcharge and cess, while duplicate taxation is excluded...
Cost-to-cost reimbursement of seconded employees is not service consideration; transfer-pricing markup was deleted and amalgamation amortisation allow...
Crystallisation of liability supports prior-period expense deduction, while functionally distinct divisions require separate transfer-pricing benchmar...
TDS u/s 195 - payment was made towards quality rebate on export - assessee has established that it is a quality rebate with relevant documents which goes to reduce the sale and as per Article VII of DTAA between India and UK, the business profits are taxable in contracting state as the recipient is foreign company having no PE - neither TDS required nor disallowance u/s 40(a)(i)
TDS u/s 195 - payment was made towards quality rebate on export - assessee has established that it is a quality rebate with relevant documents which goes to reduce the sale and as per Article VII of DTAA between India and UK, the business profits are taxable in contracting state as the recipient is foreign company having no PE - neither TDS required nor disallowance u/s 40(a)(i)
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4905 
