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...
Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-ca...
ITAT adjudicated a dispute concerning taxability of technical services under India-Singapore DTAA. The tribunal analyzed whether maintenance and training services constituted Fees for Technical Services (FTS). After comprehensive examination of service agreements, ITAT determined that the services did not transfer technical skills or expertise enabling technology application. Consequently, the income derived from such services was deemed non-taxable in India. The tribunal ruled in favor of the assessee, rejecting revenue's contention of taxable income, thus precluding tax liability under the bilateral tax treaty's provisions.
ITAT adjudicated a dispute concerning taxability of technical services under India-Singapore DTAA. The tribunal analyzed whether maintenance and training services constituted Fees for Technical Services (FTS). After comprehensive examination of service agreements, ITAT determined that the services did not transfer technical skills or expertise enabling technology application. Consequently, the income derived from such services was deemed non-taxable in India. The tribunal ruled in favor of the assessee, rejecting revenue's contention of taxable income, thus precluding tax liability under the bilateral tax treaty's provisions.
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