Reverse charge and assignment of royalty collection: exemption for excess royalty collectors subject to reconciliation; leaseholders remain liable und...
Authorization requirements for customs brokers and benami shipping bills: tribunal upholds licence revocation and penalties after COVID time limit fou...
Eligibility for notification exemption on imported fertilizers challenged; penalty, interest and confiscation set aside after voluntary payment and no...
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 4813 
Join Channel 
