Transfer-pricing comparability permits fresh objections and filters where software service comparables are functionally unsuitable for arm's-length pr...
Territorial rendering requirement excludes China-based management and consultancy services from fees for technical services under the India-China DTAA...
FEMA borrowing restrictions bind charitable trusts, and civil penalties apply without proving intent for delayed repayment of non-resident rupee loans...
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
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4881 
