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...
Prospective sugar export prohibition required registered letters of credit; private contracts and export quotas created no enforceable continuation ri...
Retroactive interim-moratorium exclusion permits protective asset disclosure and preservation measures against personal guarantors pending arbitration...
TDS u/s 195 - disallowance u/s. 40(a)(i) for non deduction of TDS on payment to non-resident which is in nature of FTS(Fee for Technical Service) - beneficial provisions of India-Netherland DTAA - The services in question did not meet the criteria of 'make available' under the India-Netherlands tax treaty. Hence, the payments for these services were not subject to TDS under section 195 and not disallowable under section 40(a)(i). - AT
TDS u/s 195 - disallowance u/s. 40(a)(i) for non deduction of TDS on payment to non-resident which is in nature of FTS(Fee for Technical Service) - beneficial provisions of India-Netherland DTAA - The services in question did not meet the criteria of 'make available' under the India-Netherlands tax treaty. Hence, the payments for these services were not subject to TDS under section 195 and not disallowable under section 40(a)(i). - AT
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