Political contribution deductions require genuine transactions; banking records and party registration alone cannot defeat evidence of accommodation e...
Post-death GST liability permits fresh proceedings against legal representatives, while discontinued-business recovery remains limited to the inherite...
Non-confirmation of FEMA seizure prevents adjudicators from overriding pending appellate findings on recorded reasons and suspected foreign asset hold...
TP Adjustment - Adjustment in the transaction of payment of royalty - Royalty payments made by the subsidiary for using certain intangible properties and services. - The Tribunal acknowledged the addendum to the agreement as a legitimate clarification of the original intent, despite being executed retrospectively. It emphasized that the addendum did not introduce new terms but clarified the existing understanding regarding the scope of "Third Parties" and royalty payments. - The Tribunal rejected the Revenue's narrower interpretation of "Third Parties" that excluded transactions through Teleperformance USA. It affirmed that services rendered to Teleperformance USA's clients, facilitated by the subsidiary, qualified for royalty payments, aligning with the agreement's broader definition of Third Parties. - The Tribunal concluded that the royalty payments were in accordance with the arm's length principle.
TP Adjustment - Adjustment in the transaction of payment of royalty - Royalty payments made by the subsidiary for using certain intangible properties and services. - The Tribunal acknowledged the addendum to the agreement as a legitimate clarification of the original intent, despite being executed retrospectively. It emphasized that the addendum did not introduce new terms but clarified the existing understanding regarding the scope of "Third Parties" and royalty payments. - The Tribunal rejected the Revenue's narrower interpretation of "Third Parties" that excluded transactions through Teleperformance USA. It affirmed that services rendered to Teleperformance USA's clients, facilitated by the subsidiary, qualified for royalty payments, aligning with the agreement's broader definition of Third Parties. - The Tribunal concluded that the royalty payments were in accordance with the arm's length principle.
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TaxTMI 
TaxTMI 
