Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
Prospective sugar export prohibition required registered letters of credit; private contracts and export quotas created no enforceable continuation ri...
Retroactive interim-moratorium exclusion permits protective asset disclosure and preservation measures against personal guarantors pending arbitration...
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ITAT resolved a tax dispute involving a UK-based engineering consultancy firm's income from services rendered in India. The Tribunal determined that payments received for consulting engineering services constitute business income under Article 7 of India-UK DTAA, not Fees for Technical Services (FTS). Since the company lacked a Permanent Establishment in India, the income was deemed non-taxable in India. The Tribunal upheld the assessee's position, consistent with its prior decisions in similar cases, and allowed the appeal, effectively exempting the income from Indian taxation.
ITAT resolved a tax dispute involving a UK-based engineering consultancy firm's income from services rendered in India. The Tribunal determined that payments received for consulting engineering services constitute business income under Article 7 of India-UK DTAA, not Fees for Technical Services (FTS). Since the company lacked a Permanent Establishment in India, the income was deemed non-taxable in India. The Tribunal upheld the assessee's position, consistent with its prior decisions in similar cases, and allowed the appeal, effectively exempting the income from Indian taxation.
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