Tenet Tax Daily October 04 2014
Equity investments in AE can’t be deemed as loans/advances; it’s outside the ambit of international transaction
ITAT directs AO to examine agreement with NR agents and ascertain whether services rendered by them were FTS
Tenet Tax Daily October 03 2014
Cap gains from sale of G-Securities if not taxable in UAE shall not be taxable in India as well under Indo-UAE DTAA
Tenet Tax Daily October 02 2014
Sum paid to Singaporean-Co. for logistic services wasn’t ‘FTS’ as it didn’t satisfy make available clause of DTAA
Tenet Tax Daily October 01 2014
Entities engaged in KPO engineering services couldn’t be comparables for a Co. providing back office operations
Tenet Tax Daily September 30 2014
Payments to non-resident for his translation services shall not be deemed as ‘fees for technical services’
Tenet Tax Daily September 25 2014
Only deductible expenditure could be subjected to sec. 40(a)(ia) disallowance for TDS default, says ITAT
Tenet Tax Daily September 24 2014
Secondment of employee by group Co. to Indian affiliate for managerial services constitutes its service PE in India
Tenet Tax Daily September 23 2014
Supervisory services without having control of physical sites couldn’t constitute a PE as per DTAA with Germany
Tenet Tax Daily September 18 2014
Broker assuming all risks without any right to conclude contracts on behalf of NR can’t be treated as agency PE
Tenet Tax Daily September 16 2014
Transaction between two resident entities won’t be an ‘International transaction’; no additions to be made
Tenet Tax Daily September 15 2014
Re-assessment affirmed as commission paid to foreign agent was included in cost of asset to escape TDS liability
Tenet Tax Daily September 09 2014
TNMM is most appropriate method for determining ALP of agency and marketing support services rendered to AE
Tenet Tax Daily September 03 2014
Sum received by assessee towards sharing of global telecommunication facility with NR agents wasn’t FTS
Tenet Tax Daily September 02 2014
AO couldn’t bypass directions of DRP to tax receipts for services rendered abroad in his own way
Tenet Tax Daily August 28 2014
Cos with huge turnover, abnormal profits or functional differences are excludible from comparables list
Tenet Tax Daily August 21 2014
Payment to foreign co. to conduct navigation studies at Indian port doesn’t satisfy ‘make available’ clause; no FTS
Tenet Tax Daily August 20 2014