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...
TDS u/s 195 - section 195 itself is quite explicit in its language while providing withholding of tax in respect of any payment, which is chargeable to tax in India. Since, the management fee paid by assessee is not chargeable to tax in India in terms with Article 12(4) of India-USA DTAA, as held by the Co-ordinate Bench in case of the payee, the assessee was not required to deduct tax at source while making such payment. - AT
TDS u/s 195 - section 195 itself is quite explicit in its language while providing withholding of tax in respect of any payment, which is chargeable to tax in India. Since, the management fee paid by assessee is not chargeable to tax in India in terms with Article 12(4) of India-USA DTAA, as held by the Co-ordinate Bench in case of the payee, the assessee was not required to deduct tax at source while making such payment. - AT
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