Specified fund definition expands PAN exemption eligibility for registered alternative investment funds and qualifying International Financial Service...
Tax exemption for specified legal-services authority income applies retrospectively, subject to non-commercial activity, unchanged income sources, and...
Approved resolution plans extinguish unsubmitted pre-approval tax claims, preventing later recovery outside the insolvency process and preserving a cl...
Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Under the India-Germany DTAA, royalty and fees for technical services were taxable only on receipt basis because Article 12 uses the expressions "paid" and "payments received," so accrual-based taxation was rejected. Receipts from standard software supplied on non-exclusive, non-transferable terms were not royalty, as they did not involve use of copyright. The consortium arrangement did not create an association of persons because the parties had separate scopes, invoices, and consideration, with no joint management or profit sharing. Offshore supply profits were not taxable in India in the absence of a PE and in light of the treaty protocol. An ad hoc transfer pricing mark-up was unsustainable without proper arm's length benchmarking. Interest on the arbitration award was also held not taxable.
Under the India-Germany DTAA, royalty and fees for technical services were taxable only on receipt basis because Article 12 uses the expressions "paid" and "payments received," so accrual-based taxation was rejected. Receipts from standard software supplied on non-exclusive, non-transferable terms were not royalty, as they did not involve use of copyright. The consortium arrangement did not create an association of persons because the parties had separate scopes, invoices, and consideration, with no joint management or profit sharing. Offshore supply profits were not taxable in India in the absence of a PE and in light of the treaty protocol. An ad hoc transfer pricing mark-up was unsustainable without proper arm's length benchmarking. Interest on the arbitration award was also held not taxable.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4813 
Join Channel 
