https://www.taxtmi.com/caselaws?id=798207 Treaty chargeability limits transfer-pricing adjustments: an arm's-length determination cannot independently create Indian taxability unless the computed amount satisfies the treaty conditions governing payment, character and source. Notional interest on receivables fails without evidence of outstanding consideration and payment or credit of interest. Standardised software and connectivity receipts are not royalty where users receive no copyright, equipment or process rights; connectivity remains non-taxable business profit absent an Indian permanent establishment. Testing, quality-control, visa support and soft-skills training do not meet the make-available standard for included services where no technical capability is transferred. Lease-rental adjustments between United States residents lack an Indian source where no Indian permanent establishment bears the liability. Advance-tax interest does not apply where tax was deductible by the payer at source. en-us Mon, 31 Aug 2026 00:00:00 +0530 Thu, 03 Sep 2026 08:20:54 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=798207 Treaty chargeability limits transfer-pricing adjustments: an arm's-length determination cannot independently create Indian taxability unless the computed amount satisfies the treaty conditions governing payment, character and source. Notional interest on receivables fails without evidence of outstanding consideration and payment or credit of interest. Standardised software and connectivity receipts are not royalty where users receive no copyright, equipment or process rights; connectivity remains non-taxable business profit absent an Indian permanent establishment. Testing, quality-control, visa support and soft-skills training do not meet the make-available standard for included services where no technical capability is transferred. Lease-rental adjustments between United States residents lack an Indian source where no Indian permanent establishment bears the liability. Advance-tax interest does not apply where tax was deductible by the payer at source. Case-Laws Income Tax Mon, 31 Aug 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=798207