https://www.taxtmi.com/caselaws?id=178313 The Tribunal allowed the appeal, emphasizing the need for a thorough assessment of payments under the International Sales and Marketing Agreement (ISMA) and the application of the Double Taxation Avoidance Agreement (DTAA) to determine tax liability accurately. The Tribunal set aside the lower authorities' decisions, remitting the matter to the Assessing Officer (AO) for reconsideration based on Article-7 of the DTAA. Payments for international marketing activities were not considered royalties under the DTAA, highlighting the importance of distinguishing between reimbursement and royalty payments for tax purposes. en-us Fri, 29 Nov 2013 00:00:00 +0530 Wed, 07 Sep 2016 19:31:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=178313 The Tribunal allowed the appeal, emphasizing the need for a thorough assessment of payments under the International Sales and Marketing Agreement (ISMA) and the application of the Double Taxation Avoidance Agreement (DTAA) to determine tax liability accurately. The Tribunal set aside the lower authorities' decisions, remitting the matter to the Assessing Officer (AO) for reconsideration based on Article-7 of the DTAA. Payments for international marketing activities were not considered royalties under the DTAA, highlighting the importance of distinguishing between reimbursement and royalty payments for tax purposes. Case-Laws Income Tax Fri, 29 Nov 2013 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=178313