Revenue neutrality in domestic related-party loans can require deletion of interest transfer pricing adjustments after domestic-transaction verificati...
Pre-enactment land-sale agreements escape stamp-duty value substitution where substantial banking-channel consideration was received before Section 43...
Customs valuation and classification require comparable evidence and assessment of imported goods in their actual condition, invalidating related pena...
Income deemed to accrue or arise in India - revenue characterization - Taxability of IUC [Interconnect utility charges] as Royalty u/s 9(1)(vi) - DTAA between India and Hongkong - The Tribunal noted that there is no treaty between India and Hong Kong, the country of which the assessee is a tax resident. The Tribunal held that the payments received by the assessee cannot be held to be royalty under section 9(1)(vi) of the Act. The revenue did not establish a permanent establishment of the assessee in India to tax the receipt in India. The payments received by the assessee are considered business profits taxable in the recipient country.
Income deemed to accrue or arise in India - revenue characterization - Taxability of IUC [Interconnect utility charges] as Royalty u/s 9(1)(vi) - DTAA between India and Hongkong - The Tribunal noted that there is no treaty between India and Hong Kong, the country of which the assessee is a tax resident. The Tribunal held that the payments received by the assessee cannot be held to be royalty under section 9(1)(vi) of the Act. The revenue did not establish a permanent establishment of the assessee in India to tax the receipt in India. The payments received by the assessee are considered business profits taxable in the recipient country.
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