TNMM functional comparability requires excluding rice manufacturers from a pure Basmati rice trader's benchmark and recognising operating export recei...
Working-capital adjustment subsumes delayed-receivable effects in TNMM benchmarking of captive software-development services, avoiding separate notion...
Transfer-pricing comparability requires exclusion of financially illogical super-profit comparables and correction of unsupported annual-report and ma...
Charitable character assessment preserves Section 80G approval despite inclusive spiritual teachings and incidental religious expenditure within the s...
Penalty proceedings for cash-loan acceptance require assessment proceedings and recorded Assessing Officer satisfaction; absent these, the proceedings...
Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-ca...
Income taxable in India or not - FTS/FIS - payments received by the assessee from its Indian customers on account of Centralized Services - absence of PE in India - The Tribunal upheld CIT(A)'s decision, emphasizing the payments received for Centralized Services are not to be classified as FTS/FIS under the Act or India-USA DTAA, aligning with precedent judgments. It was highlighted that such income constitutes business profits, not taxable in India in the absence of a Permanent Establishment (PE) of the assessee, as per the DTAA.
Income taxable in India or not - FTS/FIS - payments received by the assessee from its Indian customers on account of Centralized Services - absence of PE in India - The Tribunal upheld CIT(A)'s decision, emphasizing the payments received for Centralized Services are not to be classified as FTS/FIS under the Act or India-USA DTAA, aligning with precedent judgments. It was highlighted that such income constitutes business profits, not taxable in India in the absence of a Permanent Establishment (PE) of the assessee, as per the DTAA.
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