Allocation of registration charges: contractual clause overriding statutory presumption allowed as deduction against capital gain after unrebutted doc...
Expenditure tied to investments yielding exempt income restricted to attributable costs; broader disallowance disallowed and adjustments to WDV and mi...
Admissibility of Investigative Statements invalidated reliance on coerced emails and valuation redetermination, resulting in set aside of penalties an...
Page of 4819
Press 'Enter' after typing page number.
5341 to 5360 of 96365 Results
❮
❯
❯❯
0 / 200
Expand Note
Add to Folder
No Folders have been created
+
Are you sure you want to delete "My most important" ?
Cross-border payments to a US associated enterprise were...
Cross-border payments for marketing and support services: tribunal limits unsubstantiated reimbursed expenses and remits provision accounting for verification.
Contents
Summary
Note
Bookmark
Share
✓ Copied successfully !
Print
Print Options
For full text, please login
Login to TaxTMI
Verification Pending
The Email Id has not been verified. Click on the link we have sent on
Cross-border payments to a US associated enterprise were examined for classification as fees for included services under the "make available" concept and for withholding-tax noncompliance leading to disallowance under withholding provisions. The tribunal found the nature and basis of claimed marketing, administrative and process outsourcing charges unexplained and disproportionately high (about 53% of revenue); some costs may qualify as fees for included services. Absent proper documentary bases, the tribunal directed treating separately claimed marketing expenses as allowable but limited to 20% if unsubstantiated, allowed hearing before final disallowance, and remitted accounting treatment of recurring refund provisions to the AO for verification and adjustment.
Cross-border payments to a US associated enterprise were examined for classification as fees for included services under the "make available" concept and for withholding-tax noncompliance leading to disallowance under withholding provisions. The tribunal found the nature and basis of claimed marketing, administrative and process outsourcing charges unexplained and disproportionately high (about 53% of revenue); some costs may qualify as fees for included services. Absent proper documentary bases, the tribunal directed treating separately claimed marketing expenses as allowable but limited to 20% if unsubstantiated, allowed hearing before final disallowance, and remitted accounting treatment of recurring refund provisions to the AO for verification and adjustment.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4819 
Join Channel 
