https://www.taxtmi.com/caselaws?id=243148 The ITAT Hyderabad restored the issue of arm's length pricing on interest charged on loans for fresh adjudication, directing the AO to calculate differential interest for the relevant period only. It set aside the matter of guarantee fees charged to a US subsidiary for determination of appropriate corporate guarantee rates. The purchase cost of software was held as trading goods cost, not royalty under the India-Netherlands DTAA, and no withholding tax was required, favoring the assessee. Technical consultancy payments to UK and USA subsidiaries were not fees for technical services under DTAA, decided in favor of the assessee. Communication expenses were not to be deducted from export turnover, with the issue remanded for fresh consideration. Foreign exchange gains on export business were held as eligible for deduction under section 10A, affirming they constitute trading profit or loss, decided in favor of the assessee. en-us Thu, 16 Jan 2014 00:00:00 +0530 Tue, 29 Jul 2025 17:07:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=243148 The ITAT Hyderabad restored the issue of arm's length pricing on interest charged on loans for fresh adjudication, directing the AO to calculate differential interest for the relevant period only. It set aside the matter of guarantee fees charged to a US subsidiary for determination of appropriate corporate guarantee rates. The purchase cost of software was held as trading goods cost, not royalty under the India-Netherlands DTAA, and no withholding tax was required, favoring the assessee. Technical consultancy payments to UK and USA subsidiaries were not fees for technical services under DTAA, decided in favor of the assessee. Communication expenses were not to be deducted from export turnover, with the issue remanded for fresh consideration. Foreign exchange gains on export business were held as eligible for deduction under section 10A, affirming they constitute trading profit or loss, decided in favor of the assessee. Case-Laws Income Tax Thu, 16 Jan 2014 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=243148