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...
Page of 4828
Press 'Enter' after typing page number.
161 to 180 of 96556 Results
❮
❯
❯❯
0 / 200
Expand Note
Add to Folder
No Folders have been created
+
Are you sure you want to delete "My most important" ?
The HC held that consideration received for resale or use of computer software under EULAs or distribution agreements does not constitute royalty income arising in India. Consequently, such receipts are not taxable as royalty under the Income Tax Act. The court relied on precedent to determine that no income accrues or arises in India from these transactions. Therefore, persons liable under section 195 of the Act were not required to deduct tax at source on such payments. The assessee's appeal was allowed, relieving them from the obligation to withhold tax on these payments.
The HC held that consideration received for resale or use of computer software under EULAs or distribution agreements does not constitute royalty income arising in India. Consequently, such receipts are not taxable as royalty under the Income Tax Act. The court relied on precedent to determine that no income accrues or arises in India from these transactions. Therefore, persons liable under section 195 of the Act were not required to deduct tax at source on such payments. The assessee's appeal was allowed, relieving them from the obligation to withhold tax on these payments.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4828 
Join Channel 
