Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
Prospective sugar export prohibition required registered letters of credit; private contracts and export quotas created no enforceable continuation ri...
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The case involved reimbursement of expenses u/s 195 of the Income Tax Act, concerning payments made for services rendered outside India. The payments to various entities were found to fall under exclusionary provisions of Section 9(1)(vii)(b), as they were for earning income from a source outside India. Disallowance u/s 40(a)(i) was deemed unwarranted and ordered to be deleted. Transactions with Carnegie Mellon University, Call Centre School LLC, APM Group, British Computer Society, RADTAC, and an individual for professional services were similarly analyzed and disallowances were overturned, citing legal provisions and tax residency status. The ITAT allowed the appeals of the assessee in all instances.
The case involved reimbursement of expenses u/s 195 of the Income Tax Act, concerning payments made for services rendered outside India. The payments to various entities were found to fall under exclusionary provisions of Section 9(1)(vii)(b), as they were for earning income from a source outside India. Disallowance u/s 40(a)(i) was deemed unwarranted and ordered to be deleted. Transactions with Carnegie Mellon University, Call Centre School LLC, APM Group, British Computer Society, RADTAC, and an individual for professional services were similarly analyzed and disallowances were overturned, citing legal provisions and tax residency status. The ITAT allowed the appeals of the assessee in all instances.
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