Transfer-pricing treatment of ITeS margins excludes pass-through tax recoveries and separate delayed-receivables interest after working-capital adjust...
Capacity-utilisation adjustments under TNMM can neutralise substantiated COVID-related idle costs where underutilisation materially affects profitabil...
TNMM functional comparability requires excluding rice manufacturers from a pure Basmati rice trader's benchmark and recognising operating export recei...
Working-capital adjustment subsumes delayed-receivable effects in TNMM benchmarking of captive software-development services, avoiding separate notion...
Transfer-pricing comparability requires exclusion of financially illogical super-profit comparables and correction of unsupported annual-report and ma...
Charitable character assessment preserves Section 80G approval despite inclusive spiritual teachings and incidental religious expenditure within the s...
Penalty proceedings for cash-loan acceptance require assessment proceedings and recorded Assessing Officer satisfaction; absent these, the proceedings...
Page of 4828
Press 'Enter' after typing page number.
161 to 180 of 96556 Results
❮
❯
❯❯
0 / 200
Expand Note
Add to Folder
No Folders have been created
+
Are you sure you want to delete "My most important" ?
Royalty receipts for live transmission programs were not taxable as royalties under the India-Australia DTAA. The fee received for live transmission cannot be taxed as royalty, following coordinate bench orders affirmed by the Delhi High Court. Regarding the difference in rupee amounts reported by the appellant and Culver Max Entertainment Private Ltd., the issue was restored to the AO for verification due to different exchange rates used. The receipts from Balkrishna Industries Limited were not taxable as royalties under the Income Tax Act or the India-Australia DTAA. The agreements did not indicate that Balkrishna had any claim in the logo or intellectual property beyond the event sponsorship. The consideration was not for transfer or exclusive use of copyrights, but for the right to be part of the Big Bash League as a sponsor. The appeal was allowed.
Royalty receipts for live transmission programs were not taxable as royalties under the India-Australia DTAA. The fee received for live transmission cannot be taxed as royalty, following coordinate bench orders affirmed by the Delhi High Court. Regarding the difference in rupee amounts reported by the appellant and Culver Max Entertainment Private Ltd., the issue was restored to the AO for verification due to different exchange rates used. The receipts from Balkrishna Industries Limited were not taxable as royalties under the Income Tax Act or the India-Australia DTAA. The agreements did not indicate that Balkrishna had any claim in the logo or intellectual property beyond the event sponsorship. The consideration was not for transfer or exclusive use of copyrights, but for the right to be part of the Big Bash League as a sponsor. The appeal was allowed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4828 
Join Channel 
