Transfer pricing method selection favours TNMM where medical-equipment distribution involves substantial post-import value addition and operational ri...
Post-export shipping bill conversion remains available where contemporaneous evidence supports EPCG benefits despite curable procedural omissions and ...
TDS u/s 195 - withholding tax - payments made to the foreign firms and non-residents - rendering the services was attracting and motivating the international students for taking admission in assessee’s university - it cannot be regarded as consultancy services provided to the assessee - these agents have not received the consideration in respect of their services in India or deemed to be received in India on their behalf as they do not have any PE or agent in India. The amount has been remitted directly to them outside India by the assessee. Therefore, provisions of section 5(a) is not applicable. - No TDS liability - AT
TDS u/s 195 - withholding tax - payments made to the foreign firms and non-residents - rendering the services was attracting and motivating the international students for taking admission in assessee’s university - it cannot be regarded as consultancy services provided to the assessee - these agents have not received the consideration in respect of their services in India or deemed to be received in India on their behalf as they do not have any PE or agent in India. The amount has been remitted directly to them outside India by the assessee. Therefore, provisions of section 5(a) is not applicable. - No TDS liability - AT
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