Functional comparability governs selection of support-service and IT-enabled service comparables, with verification required for unresolved data and m...
Bank account freezing requires statutory authority; anti-money-laundering compliance and KYC monitoring do not permit unilateral indefinite restrictio...
Taxability of software sale by the US entity to Indian entities - Indian subsidiary is held as DAPE [Dependent Agent Permanent Establishment] of the assessee in India - when DAPE is remunerated at arm’s length - The Tribunal, following its previous rulings, found the assessment to misinterpret the distribution agreement and BAPA, holding that if the DAPE is remunerated at arm's length, no further addition can be made.
Taxability of software sale by the US entity to Indian entities - Indian subsidiary is held as DAPE [Dependent Agent Permanent Establishment] of the assessee in India - when DAPE is remunerated at arm’s length - The Tribunal, following its previous rulings, found the assessment to misinterpret the distribution agreement and BAPA, holding that if the DAPE is remunerated at arm's length, no further addition can be made.
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