Functional comparability under TNMM requires transaction-specific FAR analysis before benchmarking business-support services provided to associated en...
Advance pricing agreement methodology can guide benchmarking for non-covered years when functions, assets, risks and activities remain materially unch...
Tax-audit exemption for substantially State-funded educational universities prevents audit-failure penalties where income qualifies for statutory exem...
Functional, asset and risk analysis excludes diversified technology companies from captive software development comparables under cost-plus arrangemen...
Mobile-phone electronic evidence failed to establish customs undervaluation, while duty survived on non-authentic origin certificates without importer...
Automotive radio classification treats integrated infotainment features as supplementary, placing complete and qualifying unassembled units under the ...
Separate corporate personality prevents directors from being personally liable for company deposits without a guarantee or independent legal undertaki...
Cloud-based communication platform subscription fees are not royalty where subscribers receive only limited, non-exclusive access and no copyright, source code, intellectual property, or embedded process is transferred. The provider's use of technology and processes to deliver the service does not give subscribers a right to use those processes. Such receipts constitute business income and are not taxable in India absent a permanent establishment. Tax deducted at source credit requires factual verification before it may be allowed in accordance with law.
Cloud-based communication platform subscription fees are not royalty where subscribers receive only limited, non-exclusive access and no copyright, source code, intellectual property, or embedded process is transferred. The provider's use of technology and processes to deliver the service does not give subscribers a right to use those processes. Such receipts constitute business income and are not taxable in India absent a permanent establishment. Tax deducted at source credit requires factual verification before it may be allowed in accordance with law.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4916 
