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...
Tax treaty exemption for operation of airline and cargo services was held applicable, the competent authority's issuance of a certificate at a reduced withholding rate rested on an incorrect belief about outstanding assessments and thus reflected non-application of mind and inconsistent administration; because assessments showed no tax payable for the airline services, the HC set aside the impugned certificate and directed issuance of a NIL-rate certificate within seven days. The court noted taxable ground-handling and engineering services remain payable and were not affected.
Tax treaty exemption for operation of airline and cargo services was held applicable, the competent authority's issuance of a certificate at a reduced withholding rate rested on an incorrect belief about outstanding assessments and thus reflected non-application of mind and inconsistent administration; because assessments showed no tax payable for the airline services, the HC set aside the impugned certificate and directed issuance of a NIL-rate certificate within seven days. The court noted taxable ground-handling and engineering services remain payable and were not affected.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4819 
Join Channel 
