Patent-settlement expenditure treated as commercially expedient revenue outlay, with foreign-law restrictions inapplicable before the prospective amen...
International transaction benchmarking restricts transfer pricing adjustments to associated-enterprise dealings, while functional comparability govern...
Joint development agreements defer taxable transfer where possession lacks part performance, while completed flats determine consideration and exempti...
TDS u/s 194J/195 - whether payment of roaming charges falls within the meaning of “FTS" - The Tribunal held that payment of roaming charges is neither in the nature of ‘FTS’ nor ‘Royalty’ and hence did not require TDS u/s 194J of the Act or under the treaties.
TDS u/s 194J/195 - whether payment of roaming charges falls within the meaning of “FTS" - The Tribunal held that payment of roaming charges is neither in the nature of ‘FTS’ nor ‘Royalty’ and hence did not require TDS u/s 194J of the Act or under the treaties.
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