Regulatory consolidation for investment advisers: SEBI issues master circular consolidating guidance and prescribing compliance, reporting, fees and s...
Reopening of assessment cannot rest solely on an audit party's opinion; reassessment under Section 147/148 is impermissible and power of revision shou...
Tested party selection: functional analysis identified the least complex unit as the appropriate tested party, altering the transfer pricing adjustmen...
Cross-charged intra-group support services under the India-UK DTAA did not meet the make available requirement for fees for technical services. The Court held that centralized support and supervision, with technical control and know-how remaining with the parent company, did not amount to transfer of technical knowledge, skill, know-how or processes to the Indian entity. Mere guidance or incidental employee skill development was insufficient because there was no material showing independent application of technical know-how by the Indian entity. The receipts were therefore not taxable as fees for technical services under Article 13, and the Revenue's appeal was dismissed.
Cross-charged intra-group support services under the India-UK DTAA did not meet the make available requirement for fees for technical services. The Court held that centralized support and supervision, with technical control and know-how remaining with the parent company, did not amount to transfer of technical knowledge, skill, know-how or processes to the Indian entity. Mere guidance or incidental employee skill development was insufficient because there was no material showing independent application of technical know-how by the Indian entity. The receipts were therefore not taxable as fees for technical services under Article 13, and the Revenue's appeal was dismissed.
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