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 ITAT ruled that GIS charges received by a UK-based foreign company from its Indian AEs for software licenses do not qualify as Fees for Technical Services under the India-UK DTAA. The Tribunal determined that subletting software licenses without providing training, customization, or technical support does not involve transfer of technical knowledge or expertise. The procurement and allocation of licenses were deemed mere administrative functions rather than specialized services. The ITAT rejected the AO's application of the "make available" clause, finding no technical knowledge was imparted to Indian entities. The Tribunal directed that such receipts be examined under business income principles and deleted the addition made by the AO. The issue of fees under section 234F was set aside to the AO for appropriate action.
The ITAT ruled that GIS charges received by a UK-based foreign company from its Indian AEs for software licenses do not qualify as Fees for Technical Services under the India-UK DTAA. The Tribunal determined that subletting software licenses without providing training, customization, or technical support does not involve transfer of technical knowledge or expertise. The procurement and allocation of licenses were deemed mere administrative functions rather than specialized services. The ITAT rejected the AO's application of the "make available" clause, finding no technical knowledge was imparted to Indian entities. The Tribunal directed that such receipts be examined under business income principles and deleted the addition made by the AO. The issue of fees under section 234F was set aside to the AO for appropriate action.
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