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...
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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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