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 - offshore supply of design and engineering inextricably linked with manufacturing and supply of equipment, not taxable as Fees for Technical Services (FTS) under domestic law or India-Austria tax treaty. Offshore supply closely linked to offshore supply of plant and equipment, cannot be segregated as basic nature and character identical. Onshore supervisory services taxable as business profits under tax treaty, not as FTS on gross basis. Receipts connected to Permanent Establishment (PE), to be taxed on net basis under Article 7. Certain other supervisory fees taxable as FTS under Article 12(4) of tax treaty, irrespective of PE. Reimbursement of expenses from Indian group companies for group information and business services not taxable as FTS, being cost sharing without profit element.
Income deemed to accrue or arise in India - offshore supply of design and engineering inextricably linked with manufacturing and supply of equipment, not taxable as Fees for Technical Services (FTS) under domestic law or India-Austria tax treaty. Offshore supply closely linked to offshore supply of plant and equipment, cannot be segregated as basic nature and character identical. Onshore supervisory services taxable as business profits under tax treaty, not as FTS on gross basis. Receipts connected to Permanent Establishment (PE), to be taxed on net basis under Article 7. Certain other supervisory fees taxable as FTS under Article 12(4) of tax treaty, irrespective of PE. Reimbursement of expenses from Indian group companies for group information and business services not taxable as FTS, being cost sharing without profit element.
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