Functional comparability under TNMM: broadcasters excluded, software distributors included, and no separate interest on receivables after working capi...
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Income accrued in India - income from rented properties held by the appellant in Australia and UK - right of the resident country to tax its residents - the expression “may be taxed” cannot be construed to mean “shall be taxable only in the resident state”, unless it is expressly stated. Provisions of Section 90(1)(a)(i) is clearly applicable to the facts of the case. - AT
Income accrued in India - income from rented properties held by the appellant in Australia and UK - right of the resident country to tax its residents - the expression “may be taxed” cannot be construed to mean “shall be taxable only in the resident state”, unless it is expressly stated. Provisions of Section 90(1)(a)(i) is clearly applicable to the facts of the case. - AT
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