Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
Royalty income earned from the OEMs on network equipment -In view of the specific clauses in the agreement between OEM's and Indian parties, it is clear that the software didn't have an independent use and is a integral part of the hardware without which the hardware cannot function. The software supplied was a copyrighted article and not a copyright right - Not taxable u/s 9 - AT
Royalty income earned from the OEMs on network equipment -In view of the specific clauses in the agreement between OEM's and Indian parties, it is clear that the software didn't have an independent use and is a integral part of the hardware without which the hardware cannot function. The software supplied was a copyrighted article and not a copyright right - Not taxable u/s 9 - AT
Note: It is a system-generated summary and is for quick reference only.
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