Tenet Tax Daily June 29 2017
Adhoc disallowance of royalty was unjustified if TPO failed to propose adjustments as per TP provisions
Matter remanded to decide whether sum paid to Singaporean Co. for providing advice & guidelines was taxable in India
Tenet Tax Daily June 23 2017
Reimbursement of travel exp. to NR for its employee deputed in India providing technical assistance wasn’t ‘FTS’
Tenet Tax Daily June 20 2017
Limitation of relief clause can’t be invoked to deny exemption on sale of debt instrument by Singaporean Co.
Tenet Tax Daily June 17 2017
Payment for software license for internal use without any permit to alter it can’t be held as royalty: ITAT
Tenet Tax Daily June 16 2017
Payment made for package of designs and drawings couldn’t be treated as royalty
Tenet Tax Daily June 15 2017
Payment made to UK based company for consultancy charges for rendering designing services rightly treated as ‘FTS’
Tenet Tax Daily June 14 2017
Margin of a company having closing year other than of assessee not to be treated as comparable
Tenet Tax Daily June 06 2017
TPO should assign reasons explaining differences in FAR analysis of comparable to reject them in relevant year
Tenet Tax Daily June 01 2017
TP adjustment on royalty was valid as assessee was unable to justify aggregation of royalty with other transaction
Tenet Tax Daily May 31 2017
TP adjustment on royalty was valid as assessee was unable to justify aggregation of royalty with other transaction
Tenet Tax Daily May 31 2017
Matter remanded by Tribunal as TPO rejected CUP method applied by assessee without assigning any reason
Tenet Tax Daily May 30 2017
Where assessee made payment to non-resident for rendering logistic services, since said services did not involve any technical skill, expertice or transfer of technical knowledge, payment in question would not fall within ambit of fee for technical services under section 9(1)(vii)
Tenet Tax Daily May 19 2017
POEM of Foreign Shipping Co. wasn’t in India as all important decisions were taken from Denmark
Tenet Tax Daily May 10 2017
Foreign entity was to be taken as tested party when relevant data for its comparison was available in public domain
Tenet Tax Daily May 01 2017
Payment made for grant of access to software without its copyright can’t be held as royalty
Tenet Tax Daily April 22 2017
No Sec. 195 TDS on payment under Secondment when it was taxed in India as salary: ITAT
Tenet Tax Daily April 19 2017
Suitable TP adjustment was to be made comparable was offered better discount than assessee
Tenet Tax Daily March 31 2017