Receipt of immovable property requires actual possession or enjoyment; redevelopment allotments exchanged for tenancy rights fall outside deemed incom...
Section 80P deduction covers Souharda credit societies, including qualifying surplus-deposit interest, subject to member KYC verification for cash dep...
Transfer-pricing benchmarking and capital-receipt principles sustained taxpayer relief, while unsupported property-advance write-offs remained disallo...
Taxability in India of receipts of foreign AEs - Fee for Technical Services (FTS) - Master Service Agreement relied upon - The Tribunal extensively reviewed the MSA, emphasizing that it established an independent contractor relationship between the Indian entity and its foreign counterparts. It highlighted that the foreign entities had ownership of the intellectual property developed, bore the risk of performance, and had an obligation to indemnify the Indian entity for errors or performance issues. - The ITAT's ruling clarifies the distinction between revenue sharing from a consolidated project and FTS, reinforcing the principle that the nature of the payment depends on the underlying contractual relationships and the actual conduct of parties. - It was held that payments made by HCLT to the foreign AEs could not be construed as FTS.
Taxability in India of receipts of foreign AEs - Fee for Technical Services (FTS) - Master Service Agreement relied upon - The Tribunal extensively reviewed the MSA, emphasizing that it established an independent contractor relationship between the Indian entity and its foreign counterparts. It highlighted that the foreign entities had ownership of the intellectual property developed, bore the risk of performance, and had an obligation to indemnify the Indian entity for errors or performance issues. - The ITAT's ruling clarifies the distinction between revenue sharing from a consolidated project and FTS, reinforcing the principle that the nature of the payment depends on the underlying contractual relationships and the actual conduct of parties. - It was held that payments made by HCLT to the foreign AEs could not be construed as FTS.
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