Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
TDS u/s 195 - Royalty and FTS payment for non deduction of TDS - Co-location services and connectivity services provided for the process of connecting by the assessee with the various customers towards making voice and data connectivity - the consideration being for the use and the right to use of the process, it is 'royalty' within the meaning of Clause (iii) of Explanation 2 to Section 9(1)(vi) of the Income Tax Act - AT
TDS u/s 195 - Royalty and FTS payment for non deduction of TDS - Co-location services and connectivity services provided for the process of connecting by the assessee with the various customers towards making voice and data connectivity - the consideration being for the use and the right to use of the process, it is 'royalty' within the meaning of Clause (iii) of Explanation 2 to Section 9(1)(vi) of the Income Tax Act - AT
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