Transfer-pricing treatment of ITeS margins excludes pass-through tax recoveries and separate delayed-receivables interest after working-capital adjust...
Capacity-utilisation adjustments under TNMM can neutralise substantiated COVID-related idle costs where underutilisation materially affects profitabil...
TNMM functional comparability requires excluding rice manufacturers from a pure Basmati rice trader's benchmark and recognising operating export recei...
Working-capital adjustment subsumes delayed-receivable effects in TNMM benchmarking of captive software-development services, avoiding separate notion...
Transfer-pricing comparability requires exclusion of financially illogical super-profit comparables and correction of unsupported annual-report and ma...
Charitable character assessment preserves Section 80G approval despite inclusive spiritual teachings and incidental religious expenditure within the s...
Penalty proceedings for cash-loan acceptance require assessment proceedings and recorded Assessing Officer satisfaction; absent these, the proceedings...
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The assessee, Adobe Systems Software Ireland Limited, is a company incorporated under Irish laws and a tax resident of Ireland per the India-Ireland tax treaty. The tribunal held that the issue of existence of a Permanent Establishment (PE) in India is covered by a coordinate bench order, which deleted additions made by the Assessing Officer. It was held that no addition was proposed by the Transfer Pricing Officer for Adobe India regarding marketing support services. Attributing profits to the alleged PE (Adobe India) would contradict Supreme Court rulings in Morgan Stanley and E-Funds cases. The tribunal rejected the reasons and conclusions on which the Assessing Officer and Dispute Resolution Panel's findings of PE existence were premised. Consequently, the additions made by the Assessing Officer were deleted on merits for the year under consideration, and the assessee's appeal was allowed.
The assessee, Adobe Systems Software Ireland Limited, is a company incorporated under Irish laws and a tax resident of Ireland per the India-Ireland tax treaty. The tribunal held that the issue of existence of a Permanent Establishment (PE) in India is covered by a coordinate bench order, which deleted additions made by the Assessing Officer. It was held that no addition was proposed by the Transfer Pricing Officer for Adobe India regarding marketing support services. Attributing profits to the alleged PE (Adobe India) would contradict Supreme Court rulings in Morgan Stanley and E-Funds cases. The tribunal rejected the reasons and conclusions on which the Assessing Officer and Dispute Resolution Panel's findings of PE existence were premised. Consequently, the additions made by the Assessing Officer were deleted on merits for the year under consideration, and the assessee's appeal was allowed.
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