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...
Application for a certificate at nil tax rate was directed to be granted on treaty-based grounds, holding that the competent authority must decide under domestic law while giving due regard to the India-USA tax treaty and must not be driven by revenue targets; the impugned refusal was quashed and a nil-rate certificate ordered within 15 days. Future-year certificates must be issued within 30 days of application unless the authority records a finding of a Permanent Establishment after issuing notice; applicants must disclose all material facts and cooperate with any PE inquiry.
Application for a certificate at nil tax rate was directed to be granted on treaty-based grounds, holding that the competent authority must decide under domestic law while giving due regard to the India-USA tax treaty and must not be driven by revenue targets; the impugned refusal was quashed and a nil-rate certificate ordered within 15 days. Future-year certificates must be issued within 30 days of application unless the authority records a finding of a Permanent Establishment after issuing notice; applicants must disclose all material facts and cooperate with any PE inquiry.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4811 
Join Channel 
