Higher depreciation for qualifying commercial vehicles, exempt-income disallowance, research deduction verification, and club-expense treatment clarif...
Charitable registration renewal cannot become an assessment of receipts, profitability or annual exemption compliance, requiring renewal and donation ...
AMP expenditure for own business is not an international transaction without an associated-enterprise arrangement, eliminating transfer pricing adjust...
Customs valuation must use comparable contemporary imports, while confiscation fines and penalties require proportionate recalculation on reassessed v...
Depositor-protection proceedings prevail over corporate insolvency, while liquidators may recover chit receivables using copies of seized company reco...
Accrual of income in India - PE in India or not? - use or right to use brand name/trade mark - the receipts cannot be treated as royalty under Article 12(3)(a) of the Tax Treaty. Similarly, the fee received cannot be treated as royalty under Article 12(3)(b) as there is no transfer of use or right to use any industrial or commercial or scientific equipments. In any case of the matter, the fees received are purely for certain services, therefore, in our view, they cannot be treated as royalty. - AT
Accrual of income in India - PE in India or not? - use or right to use brand name/trade mark - the receipts cannot be treated as royalty under Article 12(3)(a) of the Tax Treaty. Similarly, the fee received cannot be treated as royalty under Article 12(3)(b) as there is no transfer of use or right to use any industrial or commercial or scientific equipments. In any case of the matter, the fees received are purely for certain services, therefore, in our view, they cannot be treated as royalty. - AT
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4803
Join Channel
TaxTMI 
