Protective assessment cannot duplicate identical receipts under competing characterisations; remote services did not establish a taxable permanent est...
Current account treatment of overseas tournament services removed most FEMA findings, but excess EEFC remittance and delayed repatriation remained bre...
Modification of bail conditions remains available through inherent jurisdiction where onerous deposits undermine justice and cannot recover disputed d...
Merchant banker regulation consolidates registration, governance, capital, reporting, outsourcing and investor-protection requirements under an update...
The Appellate Tribunal addressed various Transfer Pricing (TP) issues. It directed the AO/TPO to consider only operating profit/cost for TP adjustment in IT enabled Services transactions. For interest on trade receivables, it mandated using market determined rates. Regarding TDS u/s 195, payments to a Thailand entity were not classified as FTS due to absence of FTS clause in India-Thailand DTAA. The AO was directed to delete the addition u/s 40(a)(ia). However, payments to a German entity were deemed FTS under India-Germany DTAA, upholding the addition u/s 40(a)(i). The appeal was partly allowed.
The Appellate Tribunal addressed various Transfer Pricing (TP) issues. It directed the AO/TPO to consider only operating profit/cost for TP adjustment in IT enabled Services transactions. For interest on trade receivables, it mandated using market determined rates. Regarding TDS u/s 195, payments to a Thailand entity were not classified as FTS due to absence of FTS clause in India-Thailand DTAA. The AO was directed to delete the addition u/s 40(a)(ia). However, payments to a German entity were deemed FTS under India-Germany DTAA, upholding the addition u/s 40(a)(i). The appeal was partly allowed.
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