Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
Data transmission equipment classification under CTSH 8517 62 remains distinct from residual classification, with exemption evidence requiring scrutin...
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.
Note: It is a system-generated summary and is for quick reference only.
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