Transfer pricing comparables and operating income principles applied to software development services, with exclusions, inclusions, and tax credit ver...
Transfer pricing on performance guarantees and overdue receivables deleted where warranty obligations were embedded and working capital adjustment alr...
Assessee filed revised return of income and Form 67 within extended due date. Assessee paid taxes on salary earned in Netherlands under Article 23 of India-Netherlands DTAA. Late filing of Form 67 cannot be reason for denying treaty benefit when salary earned abroad and tax paid in foreign country. Assessee cannot be taxed twice on same income resulting in double taxation. CIT(A) and AO erred in denying assessee's claim. Appeal allowed.
Assessee filed revised return of income and Form 67 within extended due date. Assessee paid taxes on salary earned in Netherlands under Article 23 of India-Netherlands DTAA. Late filing of Form 67 cannot be reason for denying treaty benefit when salary earned abroad and tax paid in foreign country. Assessee cannot be taxed twice on same income resulting in double taxation. CIT(A) and AO erred in denying assessee's claim. Appeal allowed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4828 
Join Channel 
