Tenet Tax Daily February 25 2015
Even prior to 2013 India-UK protocol benefit of DTAA was allowed to fiscally transparent firm established in UK
Transaction of providing loan to foreign AE at a higher rate than LIBOR was at ALP
Tenet Tax Daily February 13 2015
Co. outsourcing major portion of its business to third party couldn’t be taken as comparable for ITES provider
Tenet Tax Daily February 09 2015
TP norms would not put fetters on selection of foreign comparables if Indian Cos didn’t satisfy test of comparability
Tenet Tax Daily February 04 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 February 03 2015
“Umbrella” of combined entity level TNMM can’t be used to benchmark separate transactions on combined basis
Tenet Tax Daily January 27 2015
ITAT invokes MFN clause to import make available clause from India-Portugese DTAA into the India-Sweden DTAA
Tenet Tax Daily January 26 2015
Manufacturer of printer’s toners couldn’t be a comparable for co. engaged in manufacturing of printing inks
Tenet Tax Daily January 24 2015
Sum paid for obtaining permanent right to use design engineering services won’t fall within the purview of royalty
Tenet Tax Daily January 19 2015
Forex loss couldn’t be considered while computing ALP of purchases if sale/purchase wasn’t at pre-determined rates
Tenet Tax Daily January 16 2015
Share application money paid to AE couldn’t be held as international transaction by deeming it as lending/borrowing
Tenet Tax Daily January 15 2015
HC sets aside ruling of AAR treating damages received by shareholder of ADR on alleged fraud as taxable receipts
Tenet Tax Daily January 14 2015
Income earned by foreign co. was business profit and it wouldn’t be taxable as foreign co. had no PE in India: HC
Tenet Tax Daily January 13 2015
ITAT directs TPO to make TP adjustment by excluding comparables with related party transaction exceeding 25%
Tenet Tax Daily December 22 2014
Sum received for hiring out dredgers wasn’t taxable as royalty under Article 12 of India-Netherland DTAA
Tenet Tax Daily December 15 2014
Income from providing seismic services was taxable under sec. 44BB if it was connected with PE of NR in India
Tenet Tax Daily December 13 2014
Sum paid to NR to acquire software for in-house use without permission of commercial exploitation is royalty
Tenet Tax Daily December 12 2014
Sum received by international news agency on distribution of news and related photos in India is royalty
Tenet Tax Daily December 11 2014