Transfer pricing comparables and adjustments: Tribunal revisits loss-maker status, segmental comparability, working capital relief, and risk allocatio...
Business expenditure disallowance failed where commission, related-party salary and promotion payments were supported by records and inquiry was inade...
Accrual of Income in India - Royalty - right to use the software - overriding effect to the DTAA - from reading of the terms of the agreements, it is clear that there was no right to use the computer software - income of the assessee which was brought to tax by the Revenue authorities cannot be brought to tax and the same is directed to be deleted. - AT
Accrual of Income in India - Royalty - right to use the software - overriding effect to the DTAA - from reading of the terms of the agreements, it is clear that there was no right to use the computer software - income of the assessee which was brought to tax by the Revenue authorities cannot be brought to tax and the same is directed to be deleted. - AT
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