https://www.taxtmi.com/caselaws?id=178310 Cross-border sales and marketing payments to Marriott International, including expense reimbursements, were treated as not chargeable to tax in India because the services were rendered outside India and the treaty's make-available condition for technical services was not satisfied, so deduction at source and disallowance under section 40(a)(ia) were not sustainable. Inventory valuation was required to follow the settled cost-or-net-realisable-value, whichever is lower, principle under ordinary commercial accounting and section 145; the High Court compromise price was not treated as open-market value, so the closing stock addition was upheld. The opening stock of the succeeding year was correspondingly to be adjusted to match the revised closing stock. en-us Mon, 23 Dec 2013 00:00:00 +0530 Tue, 23 Aug 2016 11:05:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=178310 Cross-border sales and marketing payments to Marriott International, including expense reimbursements, were treated as not chargeable to tax in India because the services were rendered outside India and the treaty's make-available condition for technical services was not satisfied, so deduction at source and disallowance under section 40(a)(ia) were not sustainable. Inventory valuation was required to follow the settled cost-or-net-realisable-value, whichever is lower, principle under ordinary commercial accounting and section 145; the High Court compromise price was not treated as open-market value, so the closing stock addition was upheld. The opening stock of the succeeding year was correspondingly to be adjusted to match the revised closing stock. Case-Laws Income Tax Mon, 23 Dec 2013 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=178310