Transfer pricing comparability: one support-services company accepted, government-owned and facility-management comparables excluded, forex loss claim...
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TDS u/s 195 - professional fees paid outside India - it cannot go to the article of ‘other income’ only because of the reason that FTS article is not there in the Double Taxation Avoidance Agreement. - To bring it under article “ other Income “, it has to be established first that income stream does not fall in any other article of DTAA. Undisputedly, all the recipient are in the business of the services. Therefore there income first classify under article of Business income. - No TDS liability - AT
TDS u/s 195 - professional fees paid outside India - it cannot go to the article of ‘other income’ only because of the reason that FTS article is not there in the Double Taxation Avoidance Agreement. - To bring it under article “ other Income “, it has to be established first that income stream does not fall in any other article of DTAA. Undisputedly, all the recipient are in the business of the services. Therefore there income first classify under article of Business income. - No TDS liability - AT
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