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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ITAT allowed the appeal of the foreign taxpayer (a UK tax resident) and held that amounts received for provision of proprietary e-invoicing software and incidental training do not constitute "fees for technical services" under Article 13(4) of the India-UK DTAA. Relying on the HC's analysis, the tribunal found the requisite "make available" condition absent because the training merely enabled use of the taxpayer's e-platform and did not transfer technical know-how, processes, or rights that would allow the recipient to independently render the invoicing service. Consequently, such receipts do not accrue or arise in India as FTS and are not chargeable to tax under the Act.
ITAT allowed the appeal of the foreign taxpayer (a UK tax resident) and held that amounts received for provision of proprietary e-invoicing software and incidental training do not constitute "fees for technical services" under Article 13(4) of the India-UK DTAA. Relying on the HC's analysis, the tribunal found the requisite "make available" condition absent because the training merely enabled use of the taxpayer's e-platform and did not transfer technical know-how, processes, or rights that would allow the recipient to independently render the invoicing service. Consequently, such receipts do not accrue or arise in India as FTS and are not chargeable to tax under the Act.
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