Revenue neutrality in domestic related-party loans can require deletion of interest transfer pricing adjustments after domestic-transaction verificati...
Challenge AAR ruling - Income taxable in India or not? - TDS liability u/s 195 - whether payments to SIPCL for BSS under the Cost Contribution Arrangement ("CCA") - The High Court determined the services availed to be managerial, not technical or consultancy that "make available" technical knowledge, skill, or processes as required by Article 13 of the DTAA. - The High Court found the AAR's interpretation flawed, emphasizing that the services in question did not satisfy the criteria of "making available" technical knowledge as per the DTAA. Consequently, it set aside the AAR's order mandating tax withholding under section 195 of the Income Tax Act, 1961.
Challenge AAR ruling - Income taxable in India or not? - TDS liability u/s 195 - whether payments to SIPCL for BSS under the Cost Contribution Arrangement ("CCA") - The High Court determined the services availed to be managerial, not technical or consultancy that "make available" technical knowledge, skill, or processes as required by Article 13 of the DTAA. - The High Court found the AAR's interpretation flawed, emphasizing that the services in question did not satisfy the criteria of "making available" technical knowledge as per the DTAA. Consequently, it set aside the AAR's order mandating tax withholding under section 195 of the Income Tax Act, 1961.
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