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...
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Royalty and fees for technical services under the India-Germany DTAA are taxable on receipt rather than accrual basis. Consideration for restricted, non-exclusive standard software licences that do not transfer copyright rights is not royalty under the Act or treaty. Separate scopes of work, invoicing, consideration and no profit-and-loss sharing prevent consortium members from constituting an association of persons; joint and several liability and indemnities alone are insufficient. Offshore equipment-supply income is not taxable in India merely because it forms part of a composite project. Transfer-pricing adjustments require a prescribed method and cannot rest on an ad hoc mark-up where transaction differences are reconciled and benchmarking is undisputed.
Royalty and fees for technical services under the India-Germany DTAA are taxable on receipt rather than accrual basis. Consideration for restricted, non-exclusive standard software licences that do not transfer copyright rights is not royalty under the Act or treaty. Separate scopes of work, invoicing, consideration and no profit-and-loss sharing prevent consortium members from constituting an association of persons; joint and several liability and indemnities alone are insufficient. Offshore equipment-supply income is not taxable in India merely because it forms part of a composite project. Transfer-pricing adjustments require a prescribed method and cannot rest on an ad hoc mark-up where transaction differences are reconciled and benchmarking is undisputed.
Note: It is a system-generated summary and is for quick reference only.
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