https://www.taxtmi.com/caselaws?id=307860 CUP benchmarking based on an independent valuer's CIRIA-based certificate was accepted for charter hire charges paid to associated enterprises, and the transfer pricing adjustment was deleted. Management service receipts were treated, following prior treaty analysis in the assessee's own case, as neither royalty nor fees for technical services under Article 12 of the India-Netherlands tax treaty, so the addition was deleted. Salary reimbursement was likewise held not to constitute fees for technical services and was deleted. Interest under section 234B was held not leviable where advance tax was not payable and tax was required to be deducted at source by the payer. en-us Fri, 31 May 2019 00:00:00 +0530 Fri, 12 May 2023 21:13:28 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=307860 CUP benchmarking based on an independent valuer's CIRIA-based certificate was accepted for charter hire charges paid to associated enterprises, and the transfer pricing adjustment was deleted. Management service receipts were treated, following prior treaty analysis in the assessee's own case, as neither royalty nor fees for technical services under Article 12 of the India-Netherlands tax treaty, so the addition was deleted. Salary reimbursement was likewise held not to constitute fees for technical services and was deleted. Interest under section 234B was held not leviable where advance tax was not payable and tax was required to be deducted at source by the payer. Case-Laws Income Tax Fri, 31 May 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=307860