Section 80JJAA employee-cost deduction allowed for deployed staff but barred against transfer-pricing income enhancement, with pricing issues remanded...
Transfer-pricing methodology protects commercially genuine associated-enterprise payments, while pre-2016 secondary adjustments and related notional i...
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Cross-examination rights in Customs Broker revocation inquiries require witness examination; procedural denial may be cured through fresh adjudication...
Governmental authority status supports construction-service exemption, while pre-cutoff contract and stamp-duty compliance requires verification on re...
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Payments for project-specific architectural and structural design services to Singapore entities were not fees for technical services because the India-Singapore DTAA "make available" test was not satisfied: the services did not transfer technical knowledge, skill, know-how or processes for independent use by the assessee. As the treaty condition failed, tax was not required to be deducted under section 195, and the disallowance under section 40(a)(i) was correctly deleted. The Tribunal also followed its earlier order in the assessee's own case for the immediately preceding year, finding no distinguishing facts.
Payments for project-specific architectural and structural design services to Singapore entities were not fees for technical services because the India-Singapore DTAA "make available" test was not satisfied: the services did not transfer technical knowledge, skill, know-how or processes for independent use by the assessee. As the treaty condition failed, tax was not required to be deducted under section 195, and the disallowance under section 40(a)(i) was correctly deleted. The Tribunal also followed its earlier order in the assessee's own case for the immediately preceding year, finding no distinguishing facts.
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