Pharmaceutical promotion and transfer-pricing comparability principles limited disallowances, while uncorroborated search allegations and unsupported ...
Business expenditure substantiation supports scrap credits, statutory payments and expense claims, while depreciation requires proof of actual busines...
TDS u/s 195 - payment received for interconnect usage charges - transaction with non-treaty country - The assessee contested the taxability of these payments as "royalty" and argued for the consideration of DTAA provisions. The Tribunal following the decision of the High Court's judgment, clarified that DTAA can indeed be considered in such proceedings and that amendments to the Income Tax Act do not automatically amend DTAA provisions. The ITAT further held that payments made to non-resident telecom operators for interconnect services are not taxable as royalty. Additionally, it affirmed that Income Tax Authorities lack jurisdiction to tax income arising from extraterritorial sources.
TDS u/s 195 - payment received for interconnect usage charges - transaction with non-treaty country - The assessee contested the taxability of these payments as "royalty" and argued for the consideration of DTAA provisions. The Tribunal following the decision of the High Court's judgment, clarified that DTAA can indeed be considered in such proceedings and that amendments to the Income Tax Act do not automatically amend DTAA provisions. The ITAT further held that payments made to non-resident telecom operators for interconnect services are not taxable as royalty. Additionally, it affirmed that Income Tax Authorities lack jurisdiction to tax income arising from extraterritorial sources.
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