Transfer pricing comparability: one support-services company accepted, government-owned and facility-management comparables excluded, forex loss claim...
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Income accrued in India - Characterization of income - 'Salary' or 'Profit in lieu of Salary' OR 'Business income' - The amount paid to the employees under the non compete agreement is covered by the expression 'salary / profits in lieu of salary', which is not taxable in India in view of Article 16 of DTAA.
Income accrued in India - Characterization of income - 'Salary' or 'Profit in lieu of Salary' OR 'Business income' - The amount paid to the employees under the non compete agreement is covered by the expression 'salary / profits in lieu of salary', which is not taxable in India in view of Article 16 of DTAA.
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