Tenet Tax Daily May 05 2015
No deemed income of NR u/s 9 when it had established Liaison office in India to purchase goods for export
Non-resident co.’s service of preparing finance scheme and arranging national and international loans, was ‘consultancy service’
Tenet Tax Daily May 04 2015
No agency PE under India-France DTAA even if agent is wholly dependent on foreign Co. unless transaction isn’t at ALP
Tenet Tax Daily April 28 2015
TP adjustment is to be made only in respect of purchases made from AE and not from unrelated parties
Tenet Tax Daily April 27 2015
TP norms would not put fetters on selection of foreign comparables if Indian Cos didn’t satisfy test of comparability
Tenet Tax Daily April 16 2015
NR rendering support services to Indian affiliate via seconded employees constituted its service PE in India
Tenet Tax Daily April 15 2015
AMP exp. incurred on brand promotion of foreign AE would attract TP provisions
Tenet Tax Daily April 14 2015
Sum paid on testing of ultrasonic meter wasn’t FTS as it didn’t satisfy make available clause of India-USA DTAA
Tenet Tax Daily April 07 2015
Co. outsourcing major portion of its business to third party couldn’t be taken as comparable for ITES provider
Tenet Tax Daily April 06 2015
Even prior to 2013 India-UK protocol benefit of DTAA was allowed to fiscally transparent firm established in UK
Tenet Tax Daily April 04 2015
Sum paid to NR for support services utilized in overseas contract isn’t liable to TDS
Tenet Tax Daily April 03 2015
ALP of advertisement exp. reimbursed to foreign AE couldn’t be taken at nil if it was incurred for Indian affiliate
Tenet Tax Daily March 30 2015
Commission paid to foreign agent for securing sales order won’t fall within the ambit of ‘FTS’; not liable to TDS
Tenet Tax Daily March 26 2015
Payment to NR under a composite contract for offshore supply and installation subject to TDS
Tenet Tax Daily March 23 2015
Sum paid to NR for support services utilized in overseas contract isn’t liable to TDS
Tenet Tax Daily March 03 2015
Budget 2015 – Gist of main amendments
Budget 2015 – Gist of main amendments
Sum paid on testing of ultrasonic meter wasn’t FTS as it didn’t satisfy make available clause of India-USA DTAA
Tenet Tax Daily February 28 2015