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FTS paid to NR was taxable in India as payer’s source of income from such services was in India

Tenet Tax Daily June 13 2016

Posted onon June 16, 2016
  • Corporate Tax
  • International Tax

Sum received for rendering composite service of managerial and technical nature can’t be taxed without segregation

Tenet Tax Daily June 09 2016

Posted onon June 16, 2016
  • Corporate Tax
  • Individual Taxation
  • International Tax

Assessee gets interest on refund arising due to foreign tax credit

Tenet Tax Daily June 06 2016

Posted onon June 16, 2016
  • Corporate Tax
  • International Tax

Sum paid to foreign entities to download photographs from their websites won’t be treated as Royalty

Tenet Tax Daily June 02 2016

Posted onon June 16, 2016
  • International Tax

Transactions being import/inter-State trade and goods being used only in works contract, would be exempt under Delhi VAT

Tenet Tax Daily May 31 2016

Posted onon June 1, 2016
  • Corporate Tax
  • International Tax

Loan advanced to AE couldn’t be said to be for non-business purpose if assessee and its AE were in same business

Tenet Tax Daily May 24 2016

Posted onon June 1, 2016
  • Corporate Tax
  • International Tax

Sum received for supplying of data without making available any technology for its use won’t be taxed as royalty

Tenet Tax Daily May 19 2016

Posted onon June 1, 2016
  • Corporate Tax
  • International Tax

Fee for service which is inextricably linked to sale isn’t treated as fee for included services under Indo-US DTAA

Tenet Tax Daily May 18 2016

Posted onon June 1, 2016
  • International Tax

TP adjustment set aside as footwear sold from old stock by ‘Adidas’ were treated to be from new stock by TPO

Tenet Tax Daily May 17 2016

Posted onon June 1, 2016
  • Corporate Tax
  • International Tax

No penalty for non-maintenance of TP docs if assessee furnished updated margins of earlier comparables

Tenet Tax Daily May 14 2016

Posted onon May 14, 2016
  • Corporate Tax
  • International Tax

Amendment made to sec. 40(a)(ia) by Finance Act, 2012 should be applicable retrospectively w.e.f 1/4/2005: ITAT

Tenet Tax Daily May 11 2016

Posted onon May 12, 2016
  • Corporate Tax
  • Individual Taxation
  • International Tax

Benefit of India-UK DTAA can’t be denied to a UK based partnership firm

Tenet Tax Daily May 10 2016

Posted onon May 12, 2016
  • Corporate Tax
  • International Tax

Purchase of technical data for AE couldn’t be treated as rendering of technical services

Tenet Tax Daily April 30 2016

Posted onon May 12, 2016
  • Corporate Tax
  • International Tax

No action could be taken against foreign parent Co. by issuing notices to its Indian group Co.

Tenet Tax Daily April 28 2016

Posted onon April 29, 2016
  • Corporate Tax
  • International Tax

Services rendered by NR sub-arrangers to mobilise funds outside India are not ‘FTS’: Bombay HC

Tenet Tax Daily April 22 2016

Posted onon April 23, 2016
  • Corporate Tax
  • International Tax

Failure to apply correct TP method attracts concealment penalty

Tenet Tax Daily April 21 2016

Posted onon April 23, 2016
  • Corporate Tax
  • International Tax

Effect of amendment to the Act can’t be given to DTAA unless corresponding amendment is also made to DTAA

Tenet Tax Daily April 20 2016

Posted onon April 23, 2016
  • Corporate Tax
  • International Tax

Placement agency services couldn’t be treated as ‘FTS’ under article 12 of India-US DTAA

Tenet Tax Daily April 19 2016

Posted onon April 23, 2016

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