Authority rules B+G+31 service apartment is commercial building construction, not multi-storey residential for tax classification under RERA definitio...
Resale price method upheld for distribution; assessee's margins accepted and certain transfer-pricing adjustments deleted due to documented reimbursem...
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The ITAT affirmed the CIT(A) and allowed the appeal of the assessee, holding that amounts received under the Regional Service Agreement constitute business profits under Article 7 of the India-Singapore DTAA and not "royalty" under s.9(1)(vi)/Article 12. The Tribunal found no transfer or grant of a right to use intangible property, nor any imparting of a corpus of industrial, commercial or scientific experience; services were performed outside India by regional personnel and remunerated on a cost-sharing basis with no PE in India. Accordingly the AO's royalty addition was unsustainable and the receipts are not taxable in India; decision in favour of the assessee is affirmed.
The ITAT affirmed the CIT(A) and allowed the appeal of the assessee, holding that amounts received under the Regional Service Agreement constitute business profits under Article 7 of the India-Singapore DTAA and not "royalty" under s.9(1)(vi)/Article 12. The Tribunal found no transfer or grant of a right to use intangible property, nor any imparting of a corpus of industrial, commercial or scientific experience; services were performed outside India by regional personnel and remunerated on a cost-sharing basis with no PE in India. Accordingly the AO's royalty addition was unsustainable and the receipts are not taxable in India; decision in favour of the assessee is affirmed.
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