Penny-stock additions require transaction-specific evidence; general investigation material alone cannot establish undisclosed income or accommodation...
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...
ITAT held in favour of the appellant that amounts received for rendering IT support and non-IT services are not taxable as Fee for Technical Services/Fee for Included Services under the Act or the India-UK DTAA for purposes of TDS u/s 195. The Tribunal affirmed the DRP's factual finding that "IT support" and "IT development" services were dissimilar and found no reliable evidence that technical knowledge, skill or know-how was made available to the associated enterprise in India or that the assessee enabled the AE to perform the services independently. Consequently the additions treating receipts as FTS/FIS were deleted and both grounds of appeal were allowed.
ITAT held in favour of the appellant that amounts received for rendering IT support and non-IT services are not taxable as Fee for Technical Services/Fee for Included Services under the Act or the India-UK DTAA for purposes of TDS u/s 195. The Tribunal affirmed the DRP's factual finding that "IT support" and "IT development" services were dissimilar and found no reliable evidence that technical knowledge, skill or know-how was made available to the associated enterprise in India or that the assessee enabled the AE to perform the services independently. Consequently the additions treating receipts as FTS/FIS were deleted and both grounds of appeal were allowed.
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