Functional comparability governs selection of support-service and IT-enabled service comparables, with verification required for unresolved data and m...
Bank account freezing requires statutory authority; anti-money-laundering compliance and KYC monitoring do not permit unilateral indefinite restrictio...
Income deemed to accrue or arise in India - TSIS Service Fee received - The term ‘Royalty’ is not as widely defined in India France DTAA as in the India Singapore DTAA, which was taken into consideration by the coordinate bench of the Tribunal in the case of sister concern. - AO directed to delete the addition in respect of TSIS Service Fees received by the assessee. - AT
Income deemed to accrue or arise in India - TSIS Service Fee received - The term ‘Royalty’ is not as widely defined in India France DTAA as in the India Singapore DTAA, which was taken into consideration by the coordinate bench of the Tribunal in the case of sister concern. - AO directed to delete the addition in respect of TSIS Service Fees received by the assessee. - AT
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