Call-recording requirements for institutional-investor client communications become non-mandatory, while institutional-investor status adopts the exis...
Restricted silver imports may clear under a valid import authorisation without additional status or exchange-routing requirements unless expressly imp...
Head Office cost allocation requires prescribed transfer-pricing methods; treaty ceilings bar surcharge and cess, while duplicate taxation is excluded...
Technical know-how consideration payable by an Indian resident to a non-resident for use in its Indian business is chargeable to tax in India under source-based taxation of fees for technical services, including under the applicable treaty. Release of funds by a foreign grant administrator after certification of contractual claims merely discharges the resident's contractual liability; it does not change the resident payer's identity or the consideration's character. The location from which funds are remitted is not determinative. Tax deduction at source is therefore required, and non-deduction results in disallowance under Section 40(a)(i).
Technical know-how consideration payable by an Indian resident to a non-resident for use in its Indian business is chargeable to tax in India under source-based taxation of fees for technical services, including under the applicable treaty. Release of funds by a foreign grant administrator after certification of contractual claims merely discharges the resident's contractual liability; it does not change the resident payer's identity or the consideration's character. The location from which funds are remitted is not determinative. Tax deduction at source is therefore required, and non-deduction results in disallowance under Section 40(a)(i).
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4913 
