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Company deriving revenue from medical transcription and consultancy services not comparable with ITES provider

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  • Company deriving revenue from medical transcription and consultancy services not comparable with ITES provider
Posted onon July 2, 2015

Tenet Tax Daily July 02 2015

By tenettax-team
Corporate Tax, International Tax

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Assessee selling manufactured goods to both AEs and third parties and paying royalty for using know-how of foreign holding company could not be held as contract manufacturer – royalty payment allowed
No denial of DTAA benefit to owner of ship just because charterer of ship was liable to tax under business agreement

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