https://www.taxtmi.com/caselaws?id=277888 A non-resident UK company's liaison office was not exposed to transfer pricing adjustment because the Tribunal followed its earlier view that treaty non-discrimination required net-basis taxation. Receipts under the Godavari operation and maintenance arrangement were treated as work-contract receipts, not fees for technical services, because no technical knowledge or know-how was made available to the Indian counterparty; gross-basis taxation was therefore rejected. For other Godavari and EPC project incomes, including foreign bank interest and allied receipts, the Tribunal applied its earlier directions that interest earned on bank accounts outside India was not taxable in India and related receipts were generally to be assessed on a net basis, with some ancillary issues remanded. en-us Thu, 11 Aug 2016 00:00:00 +0530 Fri, 28 Dec 2018 07:01:52 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=277888 A non-resident UK company's liaison office was not exposed to transfer pricing adjustment because the Tribunal followed its earlier view that treaty non-discrimination required net-basis taxation. Receipts under the Godavari operation and maintenance arrangement were treated as work-contract receipts, not fees for technical services, because no technical knowledge or know-how was made available to the Indian counterparty; gross-basis taxation was therefore rejected. For other Godavari and EPC project incomes, including foreign bank interest and allied receipts, the Tribunal applied its earlier directions that interest earned on bank accounts outside India was not taxable in India and related receipts were generally to be assessed on a net basis, with some ancillary issues remanded. Case-Laws Income Tax Thu, 11 Aug 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=277888