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Transfer pricing comparability prioritises reliable external CUPs and foreign-currency LIBOR benchmarks for exports, borrowings and delayed receivable...
Section 153C satisfaction and seized electronic records sustained unexplained-investment addition, subject to proportionate ownership-share verificati...
Held that receipts for the "use" or "right to use" of satellite transponders for provision of telecommunication or satellite services do not constitute "royalty." The AAR's prior determination in favour of the assessee-that payments for use of the monitoring system were not royalty-stands and was unsuccessfully challenged before the apex court. The questions posed by the Revenue do not raise any substantial question of law requiring this HC's adjudication. Further, the domestic amendment to the Income Tax Act by the Finance Act, 2012 cannot broaden the definition of "royalty" in the applicable DTAA; consequently those contentions fail and the appeals are dismissed.
Held that receipts for the "use" or "right to use" of satellite transponders for provision of telecommunication or satellite services do not constitute "royalty." The AAR's prior determination in favour of the assessee-that payments for use of the monitoring system were not royalty-stands and was unsuccessfully challenged before the apex court. The questions posed by the Revenue do not raise any substantial question of law requiring this HC's adjudication. Further, the domestic amendment to the Income Tax Act by the Finance Act, 2012 cannot broaden the definition of "royalty" in the applicable DTAA; consequently those contentions fail and the appeals are dismissed.
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