Loading...

⚠ ✕
❮ Top
☎ Help
Draft upto 3 replies to a
tax notice — FREE 🎉 ✕

150 credits · 30 days

• Basic Search → 1 Credit
• Advanced Search → 3 Credits
• Drafter → 20 to extract + 25 per issue
(≈ upto 2-3 drafts on us)

Already used our earlier 20-Credit Demo?
You are still eligible for this new 150-Credit Demo.

Activate your FREE Demo →
☰
×

By creating an account you can:

Logo TaxTMI
Call Us / Help / Feedback✕

Contact Us At :

✉ E-mail: [email protected]

✆ Call / WhatsApp at: +91 99117 96707

For more information, Check Contact Us

FAQs :

To know Frequently Asked Questions, Check FAQs

Most Asked Video Tutorials :

For more tutorials, Check Video Tutorials

Submit Feedback/Suggestion :

Email :
Please provide your email address so we can follow up on your feedback.
Category :
Description :
Min 15 characters 0/2000
TMI Blog
Home / TMI Blogs / RSS

Tribunal Rules on Software Sales Taxation, Arm's Length Compensation, and Misinterpretation of Agreements in India.

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....Taxability of software sale by the US entity to Indian entities - Indian subsidiary is held as DAPE [Dependent Agent Permanent Establishment] of the assessee in India - when DAPE is remunerated at arm’s length - The Tribunal, following its previous rulings, found the assessment to misinterpret the distribution agreement and BAPA, holding that if the DAPE is remunerated at arm's length, no further addition can be made.....