https://www.taxtmi.com/caselaws?id=444548 The Tribunal allowed the appeals of the assessee, M/s. Shell Global Solutions International B.V., on several issues. The transfer pricing adjustment matter was remanded to the TPO for fresh consideration. The Tribunal ruled in favor of the assessee regarding software royalty, fees for technical services, and taxability of revenues from L&T, determining that these did not constitute royalty or FTS, and the income source was outside India. Additionally, the Tribunal favored the assessee on the issue of interest levy under Sections 234A, 234B, 234C, and 234D, applying the Supreme Court's decision on prospective application from AY 2012-13. en-us Wed, 11 Oct 2023 00:00:00 +0530 Tue, 17 Oct 2023 11:20:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=444548 The Tribunal allowed the appeals of the assessee, M/s. Shell Global Solutions International B.V., on several issues. The transfer pricing adjustment matter was remanded to the TPO for fresh consideration. The Tribunal ruled in favor of the assessee regarding software royalty, fees for technical services, and taxability of revenues from L&T, determining that these did not constitute royalty or FTS, and the income source was outside India. Additionally, the Tribunal favored the assessee on the issue of interest levy under Sections 234A, 234B, 234C, and 234D, applying the Supreme Court's decision on prospective application from AY 2012-13. Case-Laws Income Tax Wed, 11 Oct 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=444548