Tenet Tax Daily December 02 2014
Sales incentives to employees establish LO promotional activities in India; treated as PE of foreign Co.
ITAT orders fresh adjudication as DRP had made TP addition on AMP expenses without consideringcontentions of assessee
Tenet Tax Daily December 01 2014
TPO should apply same formula to compute operating profit of assessee and its comparables, rules HC
Tenet Tax Daily November 29 2014
Export commission paid to foreign agent won’t attract TDS if such agent didn’t have PE in India
Tenet Tax Daily November 28 2014
Short deduction of tax due to application of wrong provision won’t lead to sec. 40(a)(ia) disallowance
Tenet Tax Daily November 18 2014
Sum paid to NR without deduction of tax won’t invite sec. 40(a)(i) disallowance if such sum was capitalized
Tenet Tax Daily November 17 2014
CIT(A) had to continue adjudication of TP adjustment not related with MAP proceeding initiated with US authorities
Tenet Tax Daily November 12 2014
ITAT directs re-adjudication of case as TPO had allowed less then 4 working days to assessee to respond
Tenet Tax Daily November 10 2014
Provisions of section 115A(1)(b)(AA) do not debar assessee to entre into new agreement after change of situation resulting in reduced rate of royalty
Tenet Tax Daily November 07 2014
ITAT directs AO to decide whether receipt for customized research/retail management services would royalty or FTS
Tenet Tax Daily November 04 2014
Sec. 92CA only empowers TPO to determine ALP of transaction; he can’t reject payment made to AE
Tenet Tax Daily November 01 2014
Market research exp. incurred by trader was in nature of revenue exp., says ITAT
Tenet Tax Daily October 18 2014
Co. incurring abnormal losses due to winding-up of relation with key clients are excludible from comparable lists
Tenet Tax Daily October 13 2014
Sums paid to DTH operators for placement of channels in a particular frequency couldn’t be deemed as royalty
Tenet Tax Daily October 10 2014
Income from offshore supply of cables couldn’t be attributed to PE of NR in India, says ITAT
Tenet Tax Daily October 09 2014
High Court interprets words ‘substantially’; lays down 50% threshold for indirect transfer of capital assets
Tenet Tax Daily October 08 2014
Sum paid for importing service manuals which contained instructions for usage of equipment wasn’t royalty
Tenet Tax Daily October 07 2014
Group Cos negotiating/securing contracts on behalf of foreign Co. would be deemed as service PE in India
Tenet Tax Daily October 06 2014