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...
Applicability of reduced treaty rate to dividends: the tribunal applied the IndiaUK DTAA's lower dividend rate, relying on a recent Bombay HC precedent, and directed DDT to be charged at 10% with refund of excess DDT paid. Levy of postassessment interest after an advance pricing agreement: the tribunal found the incremental income crystallised only on signing the APA and therefore advance tax could not reasonably be paid earlier; it directed deletion and refund of additional interest levied. Short grant of TDS credit: the assessing officer is directed to verify and grant TDS credit as claimed in the modified return under applicable law.
Applicability of reduced treaty rate to dividends: the tribunal applied the IndiaUK DTAA's lower dividend rate, relying on a recent Bombay HC precedent, and directed DDT to be charged at 10% with refund of excess DDT paid. Levy of postassessment interest after an advance pricing agreement: the tribunal found the incremental income crystallised only on signing the APA and therefore advance tax could not reasonably be paid earlier; it directed deletion and refund of additional interest levied. Short grant of TDS credit: the assessing officer is directed to verify and grant TDS credit as claimed in the modified return under applicable law.
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