Patent-settlement expenditure treated as commercially expedient revenue outlay, with foreign-law restrictions inapplicable before the prospective amen...
International transaction benchmarking restricts transfer pricing adjustments to associated-enterprise dealings, while functional comparability govern...
Income accrued in India - receipts of the assessee from sale of software - In view of Section 90(2) of the Income Tax Act, the assessee opts for Double Taxation Avoidance Agreement between India and UK to override the provisions of the Act as there is no corresponding amendment to the definition of the term ‘royalty’ in Article 13(3) of the aforesaid DTAA as carried out in the definition of royalty u/s 9 (1)(6) of the Act. - ITAT rightly rejected the arguments of revenue - HC
Income accrued in India - receipts of the assessee from sale of software - In view of Section 90(2) of the Income Tax Act, the assessee opts for Double Taxation Avoidance Agreement between India and UK to override the provisions of the Act as there is no corresponding amendment to the definition of the term ‘royalty’ in Article 13(3) of the aforesaid DTAA as carried out in the definition of royalty u/s 9 (1)(6) of the Act. - ITAT rightly rejected the arguments of revenue - HC
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4784
Join Channel
TaxTMI 
