Charity-run tree plantation and maintenance for environmental preservation qualifies as "charitable activity", making supplies GST-exempt under Notifi...
Drawings/designs supply and erection supervision fees from German contractor: designs non-taxable; supervision taxed as FTS/PE depending on six-month ...
Imported analyser diagnostic cartridges treated as accessories with analyser system, not standalone diagnostic reagents; extended limitation and penal...
Transfer pricing adjustment for corporate guarantees was governed by precedent in the taxpayer's own case, requiring guarantee commission to be benchmarked at 0.5% per annum for performance, lease and finance guarantees, and the adjustment was restricted accordingly. Overseas "State taxes" were held deductible unless eligible for relief under s. 90, since "tax" in s. 2(43) for s. 40(a)(ii) covers only tax chargeable under the Act; AO was directed to verify treaty relief and allow deduction if none. Payments for imported software were not "royalty" for internal-use software and no TDS was required; contrary treatment for trading software was not sustained. Disallowance under s. 14A r/w r. 8D was deleted for lack of recorded satisfaction; tax sparing credit under India-Singapore DTAA was allowed on FIFO method. - ITAT
Transfer pricing adjustment for corporate guarantees was governed by precedent in the taxpayer's own case, requiring guarantee commission to be benchmarked at 0.5% per annum for performance, lease and finance guarantees, and the adjustment was restricted accordingly. Overseas "State taxes" were held deductible unless eligible for relief under s. 90, since "tax" in s. 2(43) for s. 40(a)(ii) covers only tax chargeable under the Act; AO was directed to verify treaty relief and allow deduction if none. Payments for imported software were not "royalty" for internal-use software and no TDS was required; contrary treatment for trading software was not sustained. Disallowance under s. 14A r/w r. 8D was deleted for lack of recorded satisfaction; tax sparing credit under India-Singapore DTAA was allowed on FIFO method. - ITAT
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