Service permanent establishment requires non-auxiliary services, while arm's-length distributor remuneration precludes further profit attribution in I...
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TDS u/s 194A - Addition u/s 40(a(ia) - TDS on factoring charges - In the nature of interest or not - The transaction entered into by the assessee is with M/s SBI Global Factors Ltd is only a discounted sale consideration arising out of debts purchased by M/s SBI Global Factors Ltd from the assessee. This does not extend to the nature of debt thereby establishing that discounting / factoring charges are not in the nature of “interest” as defined in section 2(28A) - AT
TDS u/s 194A - Addition u/s 40(a(ia) - TDS on factoring charges - In the nature of interest or not - The transaction entered into by the assessee is with M/s SBI Global Factors Ltd is only a discounted sale consideration arising out of debts purchased by M/s SBI Global Factors Ltd from the assessee. This does not extend to the nature of debt thereby establishing that discounting / factoring charges are not in the nature of “interest” as defined in section 2(28A) - AT
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