Transfer pricing method selection favours TNMM where medical-equipment distribution involves substantial post-import value addition and operational ri...
Post-export shipping bill conversion remains available where contemporaneous evidence supports EPCG benefits despite curable procedural omissions and ...
Royalty receipts - income deemed to accrue or arise in India - assessee had sold software licenses to its associated enterprises and to other Indian customers - The ITAT Bangalore ruled that the income received by the software company from software sales to IBM India and others did not constitute royalties under the applicable laws and treaties. This judgment aligns with SC's interpretation and emphasizes consistency in legal interpretations across different assessment years.
Royalty receipts - income deemed to accrue or arise in India - assessee had sold software licenses to its associated enterprises and to other Indian customers - The ITAT Bangalore ruled that the income received by the software company from software sales to IBM India and others did not constitute royalties under the applicable laws and treaties. This judgment aligns with SC's interpretation and emphasizes consistency in legal interpretations across different assessment years.
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