Tenet Tax Daily January 16 2020
No ‘Agency PE’ of assessee in India if Indian subsidiary did not conclude contracts on behalf of assessee-US company
Consideration towards supply of embedded software treated as consideration for supply of goods and not royalty
Tenet Tax Daily January 15 2020
Provision of BPO services does not create service PE and hence not taxable as per DTAA.
Tenet Tax Daily January 14 2020
Company not entitled to DTAA benefit since place of effective management located in a third country
Tenet Tax Daily January 13 2020
Loss making company for Transfer Pricing analysis to include companies declaring losses consistently for 3 consecutive AYs
Tenet Tax Daily January 11 2020
Benchmarking intra-group services availed by assessee from AE – TNMM most appropriate method
Tenet Tax Daily January 10 2020
Profit Split Method adopted without examining expenses incurred by AE vis-à-vis assessee – issue remitted back
Tenet Tax Daily January 09 2020
Editing and Proof reading services not FTS and hence not taxable in India
Tenet Tax Daily January 08 2020
Channel placement fee liable for Sec. 194C TDS and not Sec. 194J TDS
Tenet Tax Daily January 07 2020
Failure by tax department to prove understatement of sale consideration 69B additions deleted
Tenet Tax Daily January 04 2020
Period during which property wasn’t legally occupied – notional rental income not taxable
Tenet Tax Daily January 03 2020
Property received on account of family settlement not taxable
Tenet Tax Daily January 02 2020
Since AO failed to conduct proper enquiry sec. 263 revision held justified: HC
Tenet Tax Daily January 01 2020
Compensation paid by builder to trust for reducing tax incidence rightly disallowed: HC
Tenet Tax Daily January 06 2020
Fact that no activities had been started towards objects of trust not valid ground for denial of Sec. 80G approval
Tenet Tax Daily December 31 2019
Initiation of prosecution proceedings upheld by HC as assessee failed to produce evidence of submitting TDS to Govt.
Tenet Tax Daily December 30 2019