Employee stock-shortage penalties do not constitute consideration for services, preventing GST collection under Schedule II in employment relationship...
Transfer-pricing treatment of ITeS margins excludes pass-through tax recoveries and separate delayed-receivables interest after working-capital adjust...
Capacity-utilisation adjustments under TNMM can neutralise substantiated COVID-related idle costs where underutilisation materially affects profitabil...
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TDS u/s 195 - Sales commission paid to foreign company - non deduction of TDS - addition u/s 40(a)(i) - ITAT upheld the CIT(A)'s decision, noting that services rendered by MSI do not fall within the ambit of Fees for Technical Services (FTS) or under Article 12 of the DTAA between India and the USA. The payment was for sales and marketing services, not constituting FTS or royalty, and did not require TDS deduction. The Revenue's appeal on this matter dismissed.
TDS u/s 195 - Sales commission paid to foreign company - non deduction of TDS - addition u/s 40(a)(i) - ITAT upheld the CIT(A)'s decision, noting that services rendered by MSI do not fall within the ambit of Fees for Technical Services (FTS) or under Article 12 of the DTAA between India and the USA. The payment was for sales and marketing services, not constituting FTS or royalty, and did not require TDS deduction. The Revenue's appeal on this matter dismissed.
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