Business deductions and transfer pricing issues: tribunal treatment of software write-offs, donation receipts, warranty provisions, and related expens...
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Application for NIL rate TDS deduction certificate u/s 197 - The High court noted that the project was in Bangladesh, and no part of it was situated in India. The payments to ICT for the project were made in Bangladesh, and the services rendered by the petitioner to ICT were governed by the DTAA (Double Taxation Avoidance Agreement) between the USA and India. Under Article 12 of the DTAA, only fees for 'included services' are taxable in the source state, not the fees for technical services in question. - Since no material showed the involvement of the petitioner's Indian PE in the project, the court inferred no taxable event had occurred in India. - Respondents directed to consider granting a nil rate TDS deduction certificate.
Application for NIL rate TDS deduction certificate u/s 197 - The High court noted that the project was in Bangladesh, and no part of it was situated in India. The payments to ICT for the project were made in Bangladesh, and the services rendered by the petitioner to ICT were governed by the DTAA (Double Taxation Avoidance Agreement) between the USA and India. Under Article 12 of the DTAA, only fees for 'included services' are taxable in the source state, not the fees for technical services in question. - Since no material showed the involvement of the petitioner's Indian PE in the project, the court inferred no taxable event had occurred in India. - Respondents directed to consider granting a nil rate TDS deduction certificate.
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