Tenet Tax Daily April 19 2018
Payment made to foreign co. for outright purchase of copyrights & technical know-how couldn’t be taxed as royalty
Salary paid in India to employee deputed abroad for rendering services not taxable in India: AAR
Tenet Tax Daily April 11 2018
Commission paid to NR for services rendered outside India not liable to tax even after withdrawal of Circular No. 23
Tenet Tax Daily April 06 2018
Section 206AA – levy of tax on outward remittances in hands of payer would be as dictated by provisions of treaty and not under section 206AA
Tenet Tax Daily March 17 2018
No DTAA benefit to Mauritian Co. on Cap gains if it had merely lent its name for making investments
Tenet Tax Daily March 16 2018
Internal TNMM for determining ALP couldn’t be rejected merely because size of uncontrolled transactions was small
Tenet Tax Daily March 07 2018
Payment by “Reliance” for outright purchase of billing software was not “royalty”: Mumbai ITAT
Tenet Tax Daily March 01 2018
ITAT remanded matter as TPO adopted TNMM method without identifying relevant comparables
Tenet Tax Daily February 06 2018
ITAT remanded matter to determine taxability of freight income earned by Singaporean co. in India
Tenet Tax Daily January 26 2018
SAP charges paid to AE for use of licensed software on intranet were taxable as royalty: Delhi ITAT
Tenet Tax Daily January 25 2018
No penalty if assessee failed to submit TP documents due to pendency of its application of shifting its head office
Tenet Tax Daily January 02 2018
Mumbai ITAT directs AO to follow Sony Ericsson’s case for benchmarking of AMP expenditure
Tenet Tax Daily December 28 2017
No penalty if assessee got TP study done by an outside expert
Tenet Tax Daily December 25 2017
Income from offshore supplies couldn’t be taxed in India in the absence of ‘business connection’
Tenet Tax Daily December 20 2017
Sum received by NR from marketing & distribution of its TV channel rights by an Indian co. wasn’t taxable in India
Tenet Tax Daily December 19 2017
Income earned by US co. on sale of off-the-shelf software in India isn’t taxable in absence of its PE: ITAT
Tenet Tax Daily December 16 2017
Interest charged at rate more than LIBOR was reasonable if loans were given without any intention to earn income
Tenet Tax Daily November 28 2017
Sum paid to NR for grant of software license for specific period couldn’t be held as royalty
Tenet Tax Daily October 19 2017