Tenet Tax Daily October 01 2015
Payment made to foreign service providers towards international toll free services is ‘FTS’
Education consultancy services provided by US based co. weren’t taxable in absence of its PE in India
Tenet Tax Daily September 30 2015
No withholding tax on foreign agency commission as revenue failed to prove that expenses were taxable in India
Tenet Tax Daily September 28 2015
ITAT applies results of MAP proceedings to hold that fee paid for strategic consultancy services isn’t ‘FTS’
Tenet Tax Daily September 26 2015
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
No disallowance of royalty paid to AE for export of goods by holding that assessee was contract manufacturer
Tenet Tax Daily September 21 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
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
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
Vessel operating between Indian ports as part of its international voyage would get benefit of Article 8 of DTAA
Tenet Tax Daily September 05 2015
No TDS on sum paid for repairing of aircraft as same was leased to foreign Co and running on international routes
Tenet Tax Daily September 02 2015
Debit note raised by foreign buyer for carrying out repairs on goods exported by assessee was allowable deduction
Tenet Tax Daily September 01 2015
TP addition deleted as one comparable selected by TPO had related party transaction above 25% of turnover
Tenet Tax Daily August 21 2015