Composite inpatient healthcare supply may retain exemption despite MRP medicine billing, while separate taxable sale characterisation remains disputed...
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...
TDS u/s 195 - liability u/s 201 and 201(1A) - Fees for Technical Services (FTS) or not - Distribution Agreement between the assessee and the foreign company - The Tribunal examined the terms of the agreements between the parties and concluded that the payments made were not in the nature of FTS. It highlighted that the agreements primarily involved the sale of integrated systems (including hardware and software) rather than the transfer of technical knowledge or expertise. - The ITAT noted that while some technical support was provided, it did not constitute the transfer of technical know-how or expertise. - The Tribunal upheld the applicability of the DTAA between India and the UK.
TDS u/s 195 - liability u/s 201 and 201(1A) - Fees for Technical Services (FTS) or not - Distribution Agreement between the assessee and the foreign company - The Tribunal examined the terms of the agreements between the parties and concluded that the payments made were not in the nature of FTS. It highlighted that the agreements primarily involved the sale of integrated systems (including hardware and software) rather than the transfer of technical knowledge or expertise. - The ITAT noted that while some technical support was provided, it did not constitute the transfer of technical know-how or expertise. - The Tribunal upheld the applicability of the DTAA between India and the UK.
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