International transaction characterisation of domestic divestment of support services business rejected; transaction between resident associated enter...
Minimum Import Price restrictions for Black Pepper, Areca-nuts and Apples upheld; procedural laying failure not fatal, notifications to be placed befo...
Transaction value between related persons requires market-equivalent pricing; importer must prove declared value mirrors ordinary international trade ...
Classification of exported insecticides under export tariff affirmed; reclassification and related penalties set aside and MEIS scrip jurisdiction rec...
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
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