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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ITAT quashed assessment order for AY 2015-16 as notice u/s 148 issued on June 28, 2021 was barred by limitation under amended provisions of section 149(1), not covered under TOLA. On merits, ITAT held license fees for live broadcasting rights do not constitute royalty under DTAA as Explanation-6 to Section 9(1)(vi) defining 'process' was not incorporated in treaty. However, for bundled contracts containing both live and recorded content, ITAT modified apportionment from assessee's claim of 5% recorded/95% live to 10% recorded/90% live coverage, with only recorded portion taxable as royalty. AO directed to apply correct tax rates distinguishing between resident and non-resident payers per treaty provisions.
ITAT quashed assessment order for AY 2015-16 as notice u/s 148 issued on June 28, 2021 was barred by limitation under amended provisions of section 149(1), not covered under TOLA. On merits, ITAT held license fees for live broadcasting rights do not constitute royalty under DTAA as Explanation-6 to Section 9(1)(vi) defining 'process' was not incorporated in treaty. However, for bundled contracts containing both live and recorded content, ITAT modified apportionment from assessee's claim of 5% recorded/95% live to 10% recorded/90% live coverage, with only recorded portion taxable as royalty. AO directed to apply correct tax rates distinguishing between resident and non-resident payers per treaty provisions.
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