Revenue neutrality in domestic related-party loans can require deletion of interest transfer pricing adjustments after domestic-transaction verificati...
Pre-enactment land-sale agreements escape stamp-duty value substitution where substantial banking-channel consideration was received before Section 43...
The Appellate Tribunal (ITAT) examined the taxability of sales commission as Fees for Technical Services (FTS) under the Act and India-USA DTAA. The Tribunal held that the sales commission received did not meet the definition of "FTS" under both the Act and the DTAA. It was noted that since the payer was previously held exempt from tax on commission payments, the same applies to the recipient. Ground No.3 was allowed in favor of the assessee, determining that sales commission is not taxable.
The Appellate Tribunal (ITAT) examined the taxability of sales commission as Fees for Technical Services (FTS) under the Act and India-USA DTAA. The Tribunal held that the sales commission received did not meet the definition of "FTS" under both the Act and the DTAA. It was noted that since the payer was previously held exempt from tax on commission payments, the same applies to the recipient. Ground No.3 was allowed in favor of the assessee, determining that sales commission is not taxable.
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