Transfer-pricing treatment of ITeS margins excludes pass-through tax recoveries and separate delayed-receivables interest after working-capital adjust...
Capacity-utilisation adjustments under TNMM can neutralise substantiated COVID-related idle costs where underutilisation materially affects profitabil...
TNMM functional comparability requires excluding rice manufacturers from a pure Basmati rice trader's benchmark and recognising operating export recei...
Working-capital adjustment subsumes delayed-receivable effects in TNMM benchmarking of captive software-development services, avoiding separate notion...
Transfer-pricing comparability requires exclusion of financially illogical super-profit comparables and correction of unsupported annual-report and ma...
Charitable character assessment preserves Section 80G approval despite inclusive spiritual teachings and incidental religious expenditure within the s...
Penalty proceedings for cash-loan acceptance require assessment proceedings and recorded Assessing Officer satisfaction; absent these, the proceedings...
Page of 4828
Press 'Enter' after typing page number.
161 to 180 of 96556 Results
❮
❯
❯❯
0 / 200
Expand Note
Add to Folder
No Folders have been created
+
Are you sure you want to delete "My most important" ?
Income taxable in India - payments received from its India customers on account of Centralized Services - Fee for Technical Services - Fee for included services - The Tribunal, after examining the agreements and services provided, concluded that the services were related to publicity, marketing, and advertisement, not technical or consultancy services. Therefore, they did not fall under the definition of FIS as per Article 12(4)(a) or (b) of the DTAA. - The Tribunal reaffirmed that the services provided were not ancillary or subsidiary to the application or enjoyment of any right, property, or information for which a royalty payment was made, thus not qualifying as FIS under Article 12(4)(a).
Income taxable in India - payments received from its India customers on account of Centralized Services - Fee for Technical Services - Fee for included services - The Tribunal, after examining the agreements and services provided, concluded that the services were related to publicity, marketing, and advertisement, not technical or consultancy services. Therefore, they did not fall under the definition of FIS as per Article 12(4)(a) or (b) of the DTAA. - The Tribunal reaffirmed that the services provided were not ancillary or subsidiary to the application or enjoyment of any right, property, or information for which a royalty payment was made, thus not qualifying as FIS under Article 12(4)(a).
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4828 
Join Channel 
