Tenet Tax Daily January 31 2017
Payment to Event Management Co. for IPL hosted in South Africa was FTS under India-UK treaty
Sum received on transfer of right to host and Promote ‘Formula F1 Race’ isn’t royalty
Tenet Tax Daily January 24 2017
Comparable selected in earlier year couldn’t be excluded in later years without any change in facts
Tenet Tax Daily January 16 2017
No addition for deposit in Swiss Bank when sec. 143(1) assessment was completed prior to search
tenet-tax-daily-december-30-2016
Indian Subsidiary held as PE as it was executing and concluding projects on behalf of foreign Parent Company
tenet-tax-daily-december-27-2016
TP use of multiple year data permissible only from 1-4-2014
tenet-tax-daily-december-26-2016
Rate of royalty is at ALP if it is approved by RBI and Ministry of Industry: Mumbai ITAT
tenet-tax-daily-december-24-2016
License fee to use a software not liable to TDS as it wasn’t taxable as royalty in AY 2009-10
tenet-tax-daily-december-23-2016
Consultancy charges in nature of FTS would be taxable in India irrespective of situs of services provided by NR
tenet-tax-daily-december-13-2016
TPO couldn’t adopt a method different from earlier year for ALP computation without assigning cogent reasons
tenet-tax-daily-december-07-2016
AO rightly raised demand on deductor on its failure to apply 20% TDS rate when payee had furnished wrong PAN: ITAT
tenet-tax-daily-november-07-2016
Legal charges paid to UK firm for setting-up of bank branch outside India wasn’t royalty: ITAT
tenet-tax-daily-november-01-2016
TP provisions aren’t applicable on transactions between Indian head office and foreign branch
tenet-tax-daily-october-27-2016
Working capital is one of the important factors for comparable study under transfer pricing
tenet-tax-daily-october-25-2016
No deduction of forex loss on loans granted to AE as assessee failed to prove that it was utilized for business of AE
tenet-tax-daily-october-20-2016
Sum paid for software without any right of utilizing copyright of said programme couldn’t be held as royalty
tenet-tax-daily-october-12-2016
No TP adjustment when it was held that foreign entity should have charged higher amount from Indian entities
tenet-tax-daily-september-14-2016
FAR analysis can’t be insisted upon in TNMM in transfer pricing
tenet-tax-daily-september-13-2016