Business expenditure deduction requires proof of genuine commission payments and commercial allowability; turnover growth alone cannot validate the cl...
Article 8 treaty coverage excluded third-party airline support services, while documented demonetisation cash receipts remained accepted business inco...
Functional comparability under TNMM requires highway contract benchmarks to reflect operation, maintenance and transfer activities, requiring fresh be...
Accrual of income in India - royalty income - supply of software - absence of PE of the assessee in India - The Tribunal held that, the payments received by the assessee were for the supply of software, not for the use of the copyright or imparting information concerning industrial, commercial or scientific experience. As a result, the payments were not taxable as royalty income under the India-China Double Taxation Avoidance Agreement.
Accrual of income in India - royalty income - supply of software - absence of PE of the assessee in India - The Tribunal held that, the payments received by the assessee were for the supply of software, not for the use of the copyright or imparting information concerning industrial, commercial or scientific experience. As a result, the payments were not taxable as royalty income under the India-China Double Taxation Avoidance Agreement.
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