Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-ca...
TDS u/s 195 - non-deduction of TDS on payment of export commission to Foreign entity in Italy - whether there is a business connection or not, must be determined based on facts and circumstances of the particular case. In our opinion there is nothing on record which indicates that SPA is carrying out its business in India owing to which any portion of its income can be attributed to its Indian operations. - AT
TDS u/s 195 - non-deduction of TDS on payment of export commission to Foreign entity in Italy - whether there is a business connection or not, must be determined based on facts and circumstances of the particular case. In our opinion there is nothing on record which indicates that SPA is carrying out its business in India owing to which any portion of its income can be attributed to its Indian operations. - AT
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4828 
Join Channel 
