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Category: International Tax

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  • International Tax

AAR can only determine tax liability of applicant and not any of its affiliate or AOP

Tenet Tax Daily July 20 2013

Posted onon July 20, 2013
  • International Tax

AAR can only determine tax liability of applicant and not any of its affiliate or AOP

Posted onon July 20, 2013
  • International Tax

DRP should pass a speaking order considering all objections raised by assessee

Tenet Tax Daily July 18 2013

Posted onon July 18, 2013
  • Corporate Tax
  • International Tax

Payment for downloading licensed software is payment of ‘royalty’ subject to withholding tax

Tenet Tax Daily July 17 2013

Posted onon July 17, 2013
  • International Tax

Entities incurring losses in odd circumstances excluded from list of comparables for TP study

Tenet Tax Daily July 13 2013

Posted onon July 13, 2013
  • Corporate Tax
  • International Tax

ITAT remands matter to AO due to non examination of provisions of DTAA while taxing the receipts.

Tenet Tax Daily July 05 2013

Posted onon July 5, 2013
  • Corporate Tax
  • International Tax

Commission paid for soliciting export orders abroad isn’t taxable in India.

Tenet Tax Daily July 03 2013

Posted onon July 3, 2013
  • Corporate Tax
  • International Tax

Where assessee manufacturing sophisticated chemicals, purchased a catalyst used in oxidation process of converting oxylene to pthalic anhydride, it did not amount to payment of royalty and assessee was not required to deduct tax at source while making payment.

Tenet Tax Daily July 02 2013

Posted onon July 2, 2013
  • Corporate Tax
  • International Tax

Reimbursement of purchase price, without margin or profit or value addition, to a sister concern towards payment of purchase price on behalf of assessee is not liable to TDS

Tenet Tax Daily July 01 2013

Posted onon July 1, 2013
  • Corporate Tax
  • International Tax

Ignorance of law by Chartered Accountant of the assessee is not a reasonable cause for failure to file the audit report of international transactions

Tenet Tax Daily June 29 2013

Posted onon June 29, 2013
  • Corporate Tax
  • Individual Taxation
  • International Tax

Tax is not required to be deducted from reimbursements of salary costs of the employees of a foreign company deputed to work for the Indian company

Tenet Tax Daily June 27 2013

Posted onon June 28, 2013June 28, 2013
  • International Tax

Merely assisting a non-resident principal would not cause an agent to be considered as PE

Tenet Tax Daily June 13 2013

Posted onon June 26, 2013
  • International Tax

Product similarity is must for applying CUP method, not for TNMM.

Tenet Tax Daily June 25 2013

Posted onon June 25, 2013
  • International Tax

Inland haulage charges being income from operations of ships, are exempt in India

Tenet Tax Daily June 22 2013

Posted onon June 22, 2013
  • International Tax

Amount received by a German company from software embedded in equipment supplied by it cannot be considered as ‘royalty’

Tenet Tax Daily June 21 2013

Posted onon June 21, 2013
  • International Tax

Payment to third party through a related entity cannot be considered as “reimbursement” of expenses

Tenet Tax Daily April 15, 2013

Posted onon June 21, 2013
  • International Tax

International freight forwarding and logistic services performed by the non resident taxpayer outside India is neither Managerial, nor Technical nor Consultancy in nature and hence not taxable as Fees for Technical Services under the Income-tax Act

Tenet Tax Daily May 15, 2013

Posted onon June 20, 2013
  • International Tax

ITAT confirms TP adjustments for AMP expenditure – denies de-classification of an expenditure belonging to AMP category

Tenet Tax Daily June 20 2013

Posted onon June 20, 2013

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