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...
Retroactive interim-moratorium exclusion permits protective asset disclosure and preservation measures against personal guarantors pending arbitration...
Roaming charges paid by telecom operators to other operators constitute "fees for technical services" u/s 194J, attracting TDS obligation, as human intervention and technical expertise are integral and indispensable components for smooth, efficient, uninterrupted roaming services encompassing coordination, troubleshooting, customer support, billing, and network selection/activation. Roaming service is not mere connection but seamless service requiring continuous human monitoring and expertise. Tribunal erred by restricting consideration to initial connection stage, overlooking entirety of roaming period and human intervention aspects. Matter remanded to Tribunal for fresh consideration considering all relevant factors and Apex Court directions in Bharati Cellular case.
Roaming charges paid by telecom operators to other operators constitute "fees for technical services" u/s 194J, attracting TDS obligation, as human intervention and technical expertise are integral and indispensable components for smooth, efficient, uninterrupted roaming services encompassing coordination, troubleshooting, customer support, billing, and network selection/activation. Roaming service is not mere connection but seamless service requiring continuous human monitoring and expertise. Tribunal erred by restricting consideration to initial connection stage, overlooking entirety of roaming period and human intervention aspects. Matter remanded to Tribunal for fresh consideration considering all relevant factors and Apex Court directions in Bharati Cellular case.
Note: It is a system-generated summary and is for quick reference only.