Tenet Tax Daily September 26 2015
ITAT applies results of MAP proceedings to hold that fee paid for strategic consultancy services isn’t ‘FTS’
Transactions between Head office and foreign branch aren’t international transactions under transfer pricing
Tenet Tax Daily September 25 2015
Sum paid to purchase software isn’t royalty as there is no transfer of copyright or patent of software product
Tenet Tax Daily September 24 2015
Payer can’t escape TDS liability on basis of Form 15G if amount of interest exceeds basic exemption limit of payee
Tenet Tax Daily September 23 2015
Income in Form 26AS doesn’t show that it belongs to assessee if fraudster obtained it in assessee’s name
Tenet Tax Daily September 22 2015
No disallowance of royalty paid to AE for export of goods by holding that assessee was contract manufacturer
Tenet Tax Daily September 21 2015
Sum received for permitting installation of Telecom Tower on terrace is taxable as income from house property
Tenet Tax Daily September 19 2015
Forex loss in forward contract isn’t speculative as contract is made to hedge loss in export-import transaction
Tenet Tax Daily September 18 2015
PLI of BPO can’t be compared with PLI of KPO for transfer pricing analysis
Tenet Tax Daily September 17 2015
Landing and parking charges for Aircrafts are not for ‘use of land’; attract Sec. 194C TDS
Tenet Tax Daily September 16 2015
Assessment on facts later found to be false won’t bar re-assessment by AO
Tenet Tax Daily September 15 2015
Detention order passed against detenu after considering his past activities of smuggling wasn’t illegal
Tenet Tax Daily September 14 2015
Abnormal cost incurred by a startup is to be excluded for benchmarking it with other Cos which aren’t startups
Tenet Tax Daily September 12 2015
Petitioner couldn’t be prosecuted for defaulting in complying with buy-back norms if no public offer was made
Tenet Tax Daily September 11 2015
Portfolio management services aren’t comparable with investment research and advisory services for TP study
Tenet Tax Daily September 10 2015
Delhi ITAT rejects ‘bright line test’ for adjustment of AMP exp. by following ratio of ‘Sony Ericsson’ case
Tenet Tax Daily September 09 2015
TP provisions not applicable on issue of shares to foreign AE; ITAT follows ratio of ‘Vodafone’ case
Tenet Tax Daily September 08 2015
Forex gain or loss, being an operating item would be adjusted while calculating margin of comparables
Tenet Tax Daily September 07 2015