Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
Income deemed to accrue or arise in India - receipts of subscription fees - The ITAT had found that it did not involve the transfer of copyright or the provision of technical or consultancy services that make available technical knowledge or processes to the subscriber. - The High court agreed with the Tribunal's decision, emphasizing that the provision of access to a legal database does not constitute the rendering of any technical or consultancy service that would make technical knowledge, experience, skill, know-how, or processes available to the subscriber, thereby not falling within the ambit of FTS as defined by the relevant DTAA and the Act.
Income deemed to accrue or arise in India - receipts of subscription fees - The ITAT had found that it did not involve the transfer of copyright or the provision of technical or consultancy services that make available technical knowledge or processes to the subscriber. - The High court agreed with the Tribunal's decision, emphasizing that the provision of access to a legal database does not constitute the rendering of any technical or consultancy service that would make technical knowledge, experience, skill, know-how, or processes available to the subscriber, thereby not falling within the ambit of FTS as defined by the relevant DTAA and the Act.
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