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...
Clubbing of income of Non-resident and Permanent Establishment (PE) - Levy of surcharge at 5% as against assessee’s claim of 2% - The royalty and Fee for Technical Services (FTS) income of the assessee, a non-resident corporate entity, should not be clubbed with the income of the Permanent Establishment for the purpose of surcharge under domestic law, as it is governed under the India-Germany Double Taxation Avoidance Agreement (DTAA). - The DTAA specifies a maximum tax rate of 10% on such income, and the imposition of a higher surcharge would violate this agreement. - AT
Clubbing of income of Non-resident and Permanent Establishment (PE) - Levy of surcharge at 5% as against assessee’s claim of 2% - The royalty and Fee for Technical Services (FTS) income of the assessee, a non-resident corporate entity, should not be clubbed with the income of the Permanent Establishment for the purpose of surcharge under domestic law, as it is governed under the India-Germany Double Taxation Avoidance Agreement (DTAA). - The DTAA specifies a maximum tax rate of 10% on such income, and the imposition of a higher surcharge would violate this agreement. - AT
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