Patent-settlement expenditure treated as commercially expedient revenue outlay, with foreign-law restrictions inapplicable before the prospective amen...
International transaction benchmarking restricts transfer pricing adjustments to associated-enterprise dealings, while functional comparability govern...
Joint development agreements defer taxable transfer where possession lacks part performance, while completed flats determine consideration and exempti...
TDS u/s 195 - TDS on overseas payment - Annual Payment made to the international boards through affiliation with IBO, Cambridge etc. under the head authorization fee, fee for enrolment, license fee, registration fee - assessee in default u/s 201/201(1A) - ITAT observed that the assessee failed to provide a basis for lump sum payments made to overseas institutions. Emphasized the importance of analyzing the basis of invoices raised by overseas institutions. Matter was remanded back to the Assessing Officer to understand the basis of lump sum fees and discounts offered to the assessee.
TDS u/s 195 - TDS on overseas payment - Annual Payment made to the international boards through affiliation with IBO, Cambridge etc. under the head authorization fee, fee for enrolment, license fee, registration fee - assessee in default u/s 201/201(1A) - ITAT observed that the assessee failed to provide a basis for lump sum payments made to overseas institutions. Emphasized the importance of analyzing the basis of invoices raised by overseas institutions. Matter was remanded back to the Assessing Officer to understand the basis of lump sum fees and discounts offered to the assessee.
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