Patent-settlement expenditure treated as commercially expedient revenue outlay, with foreign-law restrictions inapplicable before the prospective amen...
International transaction benchmarking restricts transfer pricing adjustments to associated-enterprise dealings, while functional comparability govern...
Joint development agreements defer taxable transfer where possession lacks part performance, while completed flats determine consideration and exempti...
TDS u/s 195 - sales commission expenses paid to agents outside India - The commission income earned by foreign agents for services rendered outside India does not accrue or arise in India and, therefore, is not subject to tax in India. Consequently, there is no requirement for the payer to deduct tax at source on such commission payments under section 40(a)(i) of the Income Tax Act, 1961. This principle is based on the proposition of law laid down by the Supreme Court of India - AT
TDS u/s 195 - sales commission expenses paid to agents outside India - The commission income earned by foreign agents for services rendered outside India does not accrue or arise in India and, therefore, is not subject to tax in India. Consequently, there is no requirement for the payer to deduct tax at source on such commission payments under section 40(a)(i) of the Income Tax Act, 1961. This principle is based on the proposition of law laid down by the Supreme Court of India - AT
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