Reopening of assessment cannot rest solely on an audit party's opinion; reassessment under Section 147/148 is impermissible and power of revision shou...
Tested party selection: functional analysis identified the least complex unit as the appropriate tested party, altering the transfer pricing adjustmen...
Whether costs incurred by the Head Office for procurement of software are deductible in computing the business profits of a permanent establishment in India under Article 7(3) of the India-Singapore DTAA: applying precedent (including Supreme Court and ITAT authority), the tribunal found that where the PE was exclusively established to distribute the procured software and the HO made the software available to the PE on a cost-to-cost basis, such procurement costs are bona fide business expenses and therefore allowable as deductions; consequently the PE's business profits were reduced by those costs and the appeal was allowed. - ITAT
Whether costs incurred by the Head Office for procurement of software are deductible in computing the business profits of a permanent establishment in India under Article 7(3) of the India-Singapore DTAA: applying precedent (including Supreme Court and ITAT authority), the tribunal found that where the PE was exclusively established to distribute the procured software and the HO made the software available to the PE on a cost-to-cost basis, such procurement costs are bona fide business expenses and therefore allowable as deductions; consequently the PE's business profits were reduced by those costs and the appeal was allowed. - ITAT
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4817 
Join Channel 
