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Cos. engaged in sales of software can’t be used as comparables for Cos. providing software development services

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Posted onon August 20, 2014

Tenet Tax Daily August 19 2014

By tenettax-team
Corporate Tax, International Tax

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Consultant doesn’t impart any experience to client when he renders consultancy services; not to be treated as royalty
Payment to foreign co. to conduct navigation studies at Indian port doesn’t satisfy ‘make available’ clause; no FTS

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