Customs relief for Strait of Hormuz maritime disruptions remains available, with existing conditions continuing unchanged through the extended validit...
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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