Head Office cost allocation requires prescribed transfer-pricing methods; treaty ceilings bar surcharge and cess, while duplicate taxation is excluded...
Cost-to-cost reimbursement of seconded employees is not service consideration; transfer-pricing markup was deleted and amalgamation amortisation allow...
Crystallisation of liability supports prior-period expense deduction, while functionally distinct divisions require separate transfer-pricing benchmar...
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...
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Customer-referral commission, calculated as a fixed percentage of sales to referred customers, does not constitute fees for technical services under the India-Netherlands tax treaty or the Act where no technical or consultancy service, design, technology, or know-how is provided or made available for independent future use. Such commission is business income and is not taxable in India under the treaty in the absence of a permanent establishment. Beneficial treaty treatment must be given effect, and withholding-tax credit relating to interest on income-tax refunds must be granted in accordance with law.
Customer-referral commission, calculated as a fixed percentage of sales to referred customers, does not constitute fees for technical services under the India-Netherlands tax treaty or the Act where no technical or consultancy service, design, technology, or know-how is provided or made available for independent future use. Such commission is business income and is not taxable in India under the treaty in the absence of a permanent establishment. Beneficial treaty treatment must be given effect, and withholding-tax credit relating to interest on income-tax refunds must be granted in accordance with law.
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