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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HC affirmed ITAT's ruling that receipts from a global online learning platform providing courses and degrees do not constitute fees for technical services (FTS) or fees for included services (FIS) under Section 9(1)(vii) and Indo-US DTAA. The court found no perversity in ITAT's factual determination that the services rendered did not involve technical elements or included services, thus rendering the income non-taxable. The HC concluded no substantial legal question emerged, effectively upholding the assessee's tax treatment of the online platform's revenue.
HC affirmed ITAT's ruling that receipts from a global online learning platform providing courses and degrees do not constitute fees for technical services (FTS) or fees for included services (FIS) under Section 9(1)(vii) and Indo-US DTAA. The court found no perversity in ITAT's factual determination that the services rendered did not involve technical elements or included services, thus rendering the income non-taxable. The HC concluded no substantial legal question emerged, effectively upholding the assessee's tax treatment of the online platform's revenue.
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