Revenue neutrality in domestic related-party loans can require deletion of interest transfer pricing adjustments after domestic-transaction verificati...
Pre-enactment land-sale agreements escape stamp-duty value substitution where substantial banking-channel consideration was received before Section 43...
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Payments for hiring International Private Leased Circuits were not liable to tax deduction at source under section 195 because the remittance was not taxable in India absent a permanent establishment. The Court followed its earlier Division Bench ruling in the assessee's own case and the Supreme Court's decision in Engineering Analysis Centre of Excellence Pvt. Ltd., holding that Explanations 4, 5 and 6 inserted by the Finance Act, 2012 could not be applied retrospectively to treat such payments as royalty. The withholding issue was decided in favour of the assessee.
Payments for hiring International Private Leased Circuits were not liable to tax deduction at source under section 195 because the remittance was not taxable in India absent a permanent establishment. The Court followed its earlier Division Bench ruling in the assessee's own case and the Supreme Court's decision in Engineering Analysis Centre of Excellence Pvt. Ltd., holding that Explanations 4, 5 and 6 inserted by the Finance Act, 2012 could not be applied retrospectively to treat such payments as royalty. The withholding issue was decided in favour of the assessee.
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