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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The government notified entry into force of a bilateral agreement and protocol between the two Contracting States to avoid double taxation and prevent fiscal evasion, effective for income arising from the first day of the fiscal year following entry into force. The treaty covers taxes on income, defines residency, permanent establishment rules, and allocation of taxing rights; prescribes withholding limits (dividends 5%/10%, interest 10%, royalties/technical fees 10%), rules on business profits, capital gains, employment income, and exemptions for certain persons. It includes provisions on non-discrimination, mutual agreement procedure, exchange of information, assistance in collection, a principal-purpose anti-abuse rule, and termination mechanics.
The government notified entry into force of a bilateral agreement and protocol between the two Contracting States to avoid double taxation and prevent fiscal evasion, effective for income arising from the first day of the fiscal year following entry into force. The treaty covers taxes on income, defines residency, permanent establishment rules, and allocation of taxing rights; prescribes withholding limits (dividends 5%/10%, interest 10%, royalties/technical fees 10%), rules on business profits, capital gains, employment income, and exemptions for certain persons. It includes provisions on non-discrimination, mutual agreement procedure, exchange of information, assistance in collection, a principal-purpose anti-abuse rule, and termination mechanics.
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