Tenet Tax Daily August 20 2015
Resale Price Method can’t be applied to benchmark export of goods to AE, rules Lucknow ITAT
Non-voice based BPO can’t be compared with voice based BPO for purpose of TP study
Tenet Tax Daily August 18 2015
ITAT rejects ‘bright line test’ for AMP expenditure; follows ratio of High Court in case of ‘Sony Ericsson’
Tenet Tax Daily July 31 2015
Royalty wasn’t taxable at concessional rate under sec. 115A if it wasn’t received in pursuance of an agreement
Tenet Tax Daily July 24 2015
Transaction of trading can’t be compared with transaction of selling goods on commission basis under TP study
Tenet Tax Daily July 16 2015
Profit arising to a German Co. from high sea sale of equipment to Indian Customer isn’t taxable in India
Tenet Tax Daily July 14 2015
JV wasn’t taxable as AOP as it was only formed to secure contract and entire work was split up between JV partners
Tenet Tax Daily July 13 2015
Sum paid to check design/quality of Fire protection system wasn’t ‘FTS’ as it didn’t satisfy make available clause
Tenet Tax Daily July 10 2015
ITAT rejects comparables as they were inappropriate due to diverse activities, brand value and economy of scales
Tenet Tax Daily July 06 2015
In view of amendment made to section 10A by Finance Act, 2000 with effect from 1-4-2001, assessee was entitled to get credit of tax deducted at Japan in respect of income exempt in India by virtue of para (2a) of article 23 of India-Japan DTAA
Tenet Tax Daily July 04 2015
No denial of DTAA benefit to owner of ship just because charterer of ship was liable to tax under business agreement
Tenet Tax Daily July 03 2015
Company deriving revenue from medical transcription and consultancy services not comparable with ITES provider
Tenet Tax Daily July 02 2015
Assessee selling manufactured goods to both AEs and third parties and paying royalty for using know-how of foreign holding company could not be held as contract manufacturer – royalty payment allowed
Tenet Tax Daily July 01 2015
Income of foreign company from hiring of equipments and rendering services to entities engaged in oil exploration in India to be taxed under section 44BB
Tenet Tax Daily June 30 2015
Issue of shares by assessee at premium to its Mauritius AE did not give rise to income from an international transaction
Tenet Tax Daily June 29 2015
Order of Commissioner (Appeals) arriving at a conclusion that provisions of article 5 of DTAA of Indo-Netherland were not applicable without discussing actual work done by assessee required readjudication
Tenet Tax Daily June 26 2015
Remittance of funds by NR to India out of incomes accrued outside India aren’t taxable in India
Tenet Tax Daily June 20 2015