Permanent Establishment and Business Connection: foreign consultancy receipts not attributable where no fixed base or corporate veil piercing establis...
Limitation period commencement and procedural inquiry rules: identity-based limitation upheld; complaints by authorised public servants need not attra...
Recurring transfer pricing and TDS disputes were decided largely by following the Tribunal's earlier orders in the assessee's own case. AMP adjustment and alleged short charge to the associated enterprise were not disturbed, advertisement and publicity expenditure was held revenue in nature despite an asserted enduring benefit, payment gateway charges were not disallowed for want of TDS, deferred contract receipts were not taxed as accrued income for the unexpired period, reimbursement of ticketing cost to MMT US was held outside section 195 because it was not taxable in India, and ESOP expenditure was treated as allowable employee compensation. Higher depreciation on computer peripherals was rejected.
Recurring transfer pricing and TDS disputes were decided largely by following the Tribunal's earlier orders in the assessee's own case. AMP adjustment and alleged short charge to the associated enterprise were not disturbed, advertisement and publicity expenditure was held revenue in nature despite an asserted enduring benefit, payment gateway charges were not disallowed for want of TDS, deferred contract receipts were not taxed as accrued income for the unexpired period, reimbursement of ticketing cost to MMT US was held outside section 195 because it was not taxable in India, and ESOP expenditure was treated as allowable employee compensation. Higher depreciation on computer peripherals was rejected.
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