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 did not have a Permanent Establishment (PE) in India, and the royalty income received during the year was taxable at 10% plus applicable surcharge and cess on a gross basis u/s 9(1)(vi). The matter regarding the quantification of royalty was restored to the Assessing Officer with directions to adopt the royalty amount as per the Advance Pricing Agreement (APA) pending execution between GIA India Lab and the Central Board of Direct Taxes (CBDT). Regarding the levy of interest u/s 234A, the Assessing Officer was directed to verify the due date extension for filing the return and allow relief accordingly. The Appellate Tribunal's order in the immediately preceding year was followed for holding that the assessee did not have a PE in India.
The assessee did not have a Permanent Establishment (PE) in India, and the royalty income received during the year was taxable at 10% plus applicable surcharge and cess on a gross basis u/s 9(1)(vi). The matter regarding the quantification of royalty was restored to the Assessing Officer with directions to adopt the royalty amount as per the Advance Pricing Agreement (APA) pending execution between GIA India Lab and the Central Board of Direct Taxes (CBDT). Regarding the levy of interest u/s 234A, the Assessing Officer was directed to verify the due date extension for filing the return and allow relief accordingly. The Appellate Tribunal's order in the immediately preceding year was followed for holding that the assessee did not have a PE in India.
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