TNMM functional comparability requires excluding rice manufacturers from a pure Basmati rice trader's benchmark and recognising operating export recei...
Working-capital adjustment subsumes delayed-receivable effects in TNMM benchmarking of captive software-development services, avoiding separate notion...
Transfer-pricing comparability requires exclusion of financially illogical super-profit comparables and correction of unsupported annual-report and ma...
Charitable character assessment preserves Section 80G approval despite inclusive spiritual teachings and incidental religious expenditure within the s...
Penalty proceedings for cash-loan acceptance require assessment proceedings and recorded Assessing Officer satisfaction; absent these, the proceedings...
Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-ca...
TDS u/s 195 - royalty payments or not - Consideration for advertisement is paid to the overseas bank account of Non-resident - the payments made by the assessee the non-resident company M/s. Facebook, Ireland cannot be considered ad "royalty payments" - There is no requirement to deduct tax at source from those payments u/s. 195 - Hence the assessee herein cannot be considered as an assessee in default u/s. 201(1) of the Act. - AT
TDS u/s 195 - royalty payments or not - Consideration for advertisement is paid to the overseas bank account of Non-resident - the payments made by the assessee the non-resident company M/s. Facebook, Ireland cannot be considered ad "royalty payments" - There is no requirement to deduct tax at source from those payments u/s. 195 - Hence the assessee herein cannot be considered as an assessee in default u/s. 201(1) of the Act. - AT
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