Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
Prospective sugar export prohibition required registered letters of credit; private contracts and export quotas created no enforceable continuation ri...
Retroactive interim-moratorium exclusion permits protective asset disclosure and preservation measures against personal guarantors pending arbitration...
The ITAT Delhi held that Bandwidth charges received by a non-resident corporate entity from India are not taxable as royalty income u/s 9(1)(vi) and Article 12(3) of India-Singapore DTAA. The Tribunal relied on its consistent view in prior assessment years and directed the AO to delete the addition. Additionally, the ITAT directed the AO to grant TDS credit for corresponding TDS deducted on interest income from an income tax refund, as claimed by the assessee.
The ITAT Delhi held that Bandwidth charges received by a non-resident corporate entity from India are not taxable as royalty income u/s 9(1)(vi) and Article 12(3) of India-Singapore DTAA. The Tribunal relied on its consistent view in prior assessment years and directed the AO to delete the addition. Additionally, the ITAT directed the AO to grant TDS credit for corresponding TDS deducted on interest income from an income tax refund, as claimed by the assessee.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4790
Join Channel
TaxTMI 
