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...
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Income deemed to accrue or arise in India - treatment of "Commission income" and receipts from "Subscription fee" - Assessee in publishing business receiving "Subscription fee" from Indian customers on behalf of affiliated publishers, revenue treated as Fees for Technical Services (FTS). Held: Services did not involve application of special skill or technical knowledge, merely promotion, sale, distribution of publications or support services. No special skills required for services under Commissionaire Agreement. Services not categorized as technical or consultancy services. Subscription amount not royalty as no copyright granted to subscribers, only copyrighted publication sold. Assessee's contention upheld, services not FTS. Decided in favor of assessee.
Income deemed to accrue or arise in India - treatment of "Commission income" and receipts from "Subscription fee" - Assessee in publishing business receiving "Subscription fee" from Indian customers on behalf of affiliated publishers, revenue treated as Fees for Technical Services (FTS). Held: Services did not involve application of special skill or technical knowledge, merely promotion, sale, distribution of publications or support services. No special skills required for services under Commissionaire Agreement. Services not categorized as technical or consultancy services. Subscription amount not royalty as no copyright granted to subscribers, only copyrighted publication sold. Assessee's contention upheld, services not FTS. Decided in favor of assessee.
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