Transfer pricing comparables and adjustments: Tribunal revisits loss-maker status, segmental comparability, working capital relief, and risk allocatio...
Business expenditure disallowance failed where commission, related-party salary and promotion payments were supported by records and inquiry was inade...
Accrual of income in India - Royalty receipts - taxation of revenue from online database of text journal and books as royalty income u/Article 12 of India US DTAA - The Tribunal concluded that since there was no transfer of legal title in the copyrighted article, and the users did not acquire any right to exploit the underlying copyright, the revenue derived from granting access to the database did not constitute royalty under Article 12 of the agreement.
Accrual of income in India - Royalty receipts - taxation of revenue from online database of text journal and books as royalty income u/Article 12 of India US DTAA - The Tribunal concluded that since there was no transfer of legal title in the copyrighted article, and the users did not acquire any right to exploit the underlying copyright, the revenue derived from granting access to the database did not constitute royalty under Article 12 of the agreement.
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