Patent-settlement expenditure treated as commercially expedient revenue outlay, with foreign-law restrictions inapplicable before the prospective amen...
International transaction benchmarking restricts transfer pricing adjustments to associated-enterprise dealings, while functional comparability govern...
Joint development agreements defer taxable transfer where possession lacks part performance, while completed flats determine consideration and exempti...
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The ITAT held that the income received by the assessee from Indian customers for providing a cloud-native machine data analytics solution did not qualify as "Fees for Technical Services" (FTS) under the Income Tax Act, 1961 and the India-US DTAA. The assessee had submitted a Tax Residency Certificate (TRC) and offered the income generated in India as business income in the resident country, as required by law. Consequently, the grounds of appeal nos. 1 to 6 filed by the assessee were allowed. Regarding TDS credit, the ITAT directed the Assessing Officer to verify and allow the same as per law.
The ITAT held that the income received by the assessee from Indian customers for providing a cloud-native machine data analytics solution did not qualify as "Fees for Technical Services" (FTS) under the Income Tax Act, 1961 and the India-US DTAA. The assessee had submitted a Tax Residency Certificate (TRC) and offered the income generated in India as business income in the resident country, as required by law. Consequently, the grounds of appeal nos. 1 to 6 filed by the assessee were allowed. Regarding TDS credit, the ITAT directed the Assessing Officer to verify and allow the same as per law.
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