https://www.taxtmi.com/caselaws?id=341947 Payments to the Singapore entity were treated as reimbursements supported by debit notes and invoices for data communication, software maintenance and related expenses, so they were not royalty or fees for technical services and no withholding tax liability arose on that basis. Credit for tax deducted at source on interest paid to the head office was allowed subject to verification of the tax actually paid, with the matter remanded for that limited exercise. The transfer pricing adjustment on commission from treasury products was also decided for the assessee, following the earlier order, with recomputation directed on the relevant transaction cost and proper consideration of comparable selection objections. en-us Wed, 19 Apr 2017 00:00:00 +0530 Fri, 21 Apr 2017 07:22:51 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=341947 Payments to the Singapore entity were treated as reimbursements supported by debit notes and invoices for data communication, software maintenance and related expenses, so they were not royalty or fees for technical services and no withholding tax liability arose on that basis. Credit for tax deducted at source on interest paid to the head office was allowed subject to verification of the tax actually paid, with the matter remanded for that limited exercise. The transfer pricing adjustment on commission from treasury products was also decided for the assessee, following the earlier order, with recomputation directed on the relevant transaction cost and proper consideration of comparable selection objections. Case-Laws Income Tax Wed, 19 Apr 2017 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=341947