Transfer pricing margin adjustments require matching treatment of non-operating income and related costs, with comparability issues reconsidered on ev...
Preliminary-expense amortisation and MAT exempt-income adjustments prevailed, while trademark costs and managerial remuneration require fresh verifica...
Export valuation requires contemporaneous evidence; unrelated invoices cannot prove overvaluation, and dual penalties on firm and partner are impermis...
Ratification of resignation acceptance validates separation retrospectively, while withdrawal may be refused through reasoned administrative discretio...
Nature-dependent electricity contracts receive new Ind AS accounting, hedge designation, transition and financial-statement disclosure requirements fr...
Alternative GST remedy permitted protective writ intervention for ex parte adjudication, preserving independent appellate review of input tax credit d...
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TDS u/s 195 - Taxability of income in India - PE in India - taxation of offshore supplies - Taxation of Fee for Technical Services (FTS) in the absence of FTS article under India-Thailand DTAA. The Tribunal held that HCIL, a subsidiary of Honda Motors Company Ltd., was not required to deduct tax at source for payments made for purchase of raw materials, components, etc. from non-resident associated enterprises as they did not have a PE in India. The Tribunal observed that the DRP and the Department had accepted that these associated enterprises did not have a PE in India. Regarding taxation of offshore supplies, the Tribunal held that since HCIL did not have a PE in India, the directions to attribute profits to operations carried out in the PE were not applicable. Concerning FTS receipts, the Tribunal held that in the absence of an FTS article in the India-Thailand DTAA, and without a PE in India, the FTS receipts were not liable to tax in India as per Section 9(1)(vii) of the Act.
TDS u/s 195 - Taxability of income in India - PE in India - taxation of offshore supplies - Taxation of Fee for Technical Services (FTS) in the absence of FTS article under India-Thailand DTAA. The Tribunal held that HCIL, a subsidiary of Honda Motors Company Ltd., was not required to deduct tax at source for payments made for purchase of raw materials, components, etc. from non-resident associated enterprises as they did not have a PE in India. The Tribunal observed that the DRP and the Department had accepted that these associated enterprises did not have a PE in India. Regarding taxation of offshore supplies, the Tribunal held that since HCIL did not have a PE in India, the directions to attribute profits to operations carried out in the PE were not applicable. Concerning FTS receipts, the Tribunal held that in the absence of an FTS article in the India-Thailand DTAA, and without a PE in India, the FTS receipts were not liable to tax in India as per Section 9(1)(vii) of the Act.
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