Business deductions and transfer pricing issues: tribunal treatment of software write-offs, donation receipts, warranty provisions, and related expens...
TEC does not have a permanent establishment in India in terms of Article 5(2)(k) of the India-USA Tax Treaty. The assessee did not have an obligation to withhold taxes at source on payments made to TEC, USA. Assessee's appeal allowed.
TEC does not have a permanent establishment in India in terms of Article 5(2)(k) of the India-USA Tax Treaty. The assessee did not have an obligation to withhold taxes at source on payments made to TEC, USA. Assessee's appeal allowed.
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