Transfer pricing comparables and operating income principles applied to software development services, with exclusions, inclusions, and tax credit ver...
Transfer pricing on performance guarantees and overdue receivables deleted where warranty obligations were embedded and working capital adjustment alr...
Rejection of an application for a withholding tax certificate resulted in the High Court holding that the Competent Authority acted arbitrarily by issuing a certificate at 15% despite existing binding precedent favouring nil withholding; the authority cannot depart from the court's settled view unless factual differences or new information justify a contrary conclusion. The court criticised delay in deciding the Section 197 application beyond the statutory period, observed that such delay frustrates the statutory purpose of preserving cash flow and avoiding interest on refunds, set aside the impugned order and directed issuance of a nil-rate certificate within 15 days.
Rejection of an application for a withholding tax certificate resulted in the High Court holding that the Competent Authority acted arbitrarily by issuing a certificate at 15% despite existing binding precedent favouring nil withholding; the authority cannot depart from the court's settled view unless factual differences or new information justify a contrary conclusion. The court criticised delay in deciding the Section 197 application beyond the statutory period, observed that such delay frustrates the statutory purpose of preserving cash flow and avoiding interest on refunds, set aside the impugned order and directed issuance of a nil-rate certificate within 15 days.
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