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...
Joint development agreements defer taxable transfer where possession lacks part performance, while completed flats determine consideration and exempti...
TDS u/s 195 OR 192 - the payment made by the assessee towards reimbursement of expenses is in the nature of salary cost of the assigned employees subject to TDS u/s 192 of the Act, hence, cannot be treated as FTS u/s 9(1)(vii) of the Act and Article 12 of the tax treaty - No TDS liability u/s 195 - AT
TDS u/s 195 OR 192 - the payment made by the assessee towards reimbursement of expenses is in the nature of salary cost of the assigned employees subject to TDS u/s 192 of the Act, hence, cannot be treated as FTS u/s 9(1)(vii) of the Act and Article 12 of the tax treaty - No TDS liability u/s 195 - AT
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