Functional comparability under TNMM supported exclusion of ITeS comparables with R&D, intangibles, diversified operations, or unavailable segmental da...
Functional comparability governs selection of support-service and IT-enabled service comparables, with verification required for unresolved data and m...
Bank account freezing requires statutory authority; anti-money-laundering compliance and KYC monitoring do not permit unilateral indefinite restrictio...
Taxability of income in India - deduction with respect to salaries paid by appellant in foreign currency outside India to expatriates working in India - Indo-Japan tax treaty. Following Emirates Commercial Bank Ltd. and Supreme Court's view in Goetze (India) Ltd., exception carved out for statutory prohibition of deduction claimed outside Return of Income not applicable in case of Tribunal or Court direction. HC quashed order denying relief to petitioner regarding deductions liable pursuant to Tribunal order.
Taxability of income in India - deduction with respect to salaries paid by appellant in foreign currency outside India to expatriates working in India - Indo-Japan tax treaty. Following Emirates Commercial Bank Ltd. and Supreme Court's view in Goetze (India) Ltd., exception carved out for statutory prohibition of deduction claimed outside Return of Income not applicable in case of Tribunal or Court direction. HC quashed order denying relief to petitioner regarding deductions liable pursuant to Tribunal order.
Note: It is a system-generated summary and is for quick reference only.