Transfer pricing adjustments for software services, corporate guarantees, expense characterisation and foreign tax credit affirmed under arm's length ...
Scientific Research approval for Sikshya O Anusandhan under section 35(1)(ii) granted subject to reporting, certification, and compliance requirements...
Taxability of transponder service fees was addressed as whether such payments constitute royalty under the India-UK tax treaty, with the tribunal applying the principle that unilateral domestic amendments do not alter treaty definitions; accordingly the amended domestic definition of process/royalty was not imported into the treaty, and payments for transponder services were held not to fall within the treaty definition of royalty, disposing of the withholding obligation under the treaty analysis. The tribunal upheld the appellate authoritys rejection of revenues contention and did not adjudicate separate issues on fees for technical services or business profits due to absence of contested grounds.
Taxability of transponder service fees was addressed as whether such payments constitute royalty under the India-UK tax treaty, with the tribunal applying the principle that unilateral domestic amendments do not alter treaty definitions; accordingly the amended domestic definition of process/royalty was not imported into the treaty, and payments for transponder services were held not to fall within the treaty definition of royalty, disposing of the withholding obligation under the treaty analysis. The tribunal upheld the appellate authoritys rejection of revenues contention and did not adjudicate separate issues on fees for technical services or business profits due to absence of contested grounds.
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