Transfer pricing comparables and operating income principles applied to software development services, with exclusions, inclusions, and tax credit ver...
Transfer pricing on performance guarantees and overdue receivables deleted where warranty obligations were embedded and working capital adjustment alr...
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.
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