https://www.taxtmi.com/caselaws?id=308979 Foreign exchange fluctuation gain from export business was treated as eligible for section 10A deduction because it arose from export operations and no contrary material was brought to disturb the consistent view taken in earlier years. Payments to the UK branch and foreign consultants were held outside section 40(a)(ia) because the recipients had no permanent establishment in India and the services did not satisfy the make available test for fees for technical services, so section 195 was not triggered. Recruitment and training expenses were not disallowed in part, as the record showed no identifiable non-business element. The transfer pricing adjustment for software services, human resources management services and credit period was rejected on the basis that the facts were identical to prior years and the distributor-based remuneration model applied. en-us Fri, 12 Apr 2013 00:00:00 +0530 Fri, 04 Aug 2023 12:06:47 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=308979 Foreign exchange fluctuation gain from export business was treated as eligible for section 10A deduction because it arose from export operations and no contrary material was brought to disturb the consistent view taken in earlier years. Payments to the UK branch and foreign consultants were held outside section 40(a)(ia) because the recipients had no permanent establishment in India and the services did not satisfy the make available test for fees for technical services, so section 195 was not triggered. Recruitment and training expenses were not disallowed in part, as the record showed no identifiable non-business element. The transfer pricing adjustment for software services, human resources management services and credit period was rejected on the basis that the facts were identical to prior years and the distributor-based remuneration model applied. Case-Laws Income Tax Fri, 12 Apr 2013 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=308979