Tenet Tax Daily August 05 2019
No FTS or Royalty wrt Interconnect usage charges paid to foreign telecom operators
Marketing & distribution of Computerized Reservation System of Foreign Co. exclusively handled by Indian subsidiary: PE created
Tenet Tax Daily July 30 2019
Subscription charges received from customers not taxable as royalty
Tenet Tax Daily July 18 2019
Payments made to Foreign Bank for providing financial services is not liable to tax as ‘FTS’
Tenet Tax Daily July 17 2019
Since benchmarking done by assessee was accepted by the TPO penalty u/s 271G was to be deleted
Tenet Tax Daily July 10 2019
Payment received on transfer of copyrighted software is not royalty: ITAT
Tenet Tax Daily June 11 2019
Commission received by Non Resident agents for export is not liable to tax in India
Tenet Tax Daily May 29 2019
ALP of international transaction couldn’t be determined by comparing price charged by other AE’s
Tenet Tax Daily May 11 2019
Subsidy received from foreign joint venture partner to contribute in joint venture co. was a capital receipt
Tenet Tax Daily April 27 2019
No TP adjustments on share purchase at high premium as it doesn’t amount to revenue receipt: Bombay HC
Tenet Tax Daily April 11 2019
ITAT quashed draft assessment order as ‘ESPN’, being NR partnership firm, wasn’t an eligible assessee u/s 144C
Tenet Tax Daily April 03 2019
Services received by ONGC from Dutch Co. not FTS in absence of transmitting of any technical knowledge
Tenet Tax Daily March 28 2019
TP method consistently followed by assessee can’t be changed by TPO if there is no change in circumstances
Tenet Tax Daily March 25 2019
No TP adjustment in absence of agreement on incurring AMP expenses for promoting AE’s brand
Tenet Tax Daily March 23 2019
TPO can apply TNMM to compute ALP even if comparable Co. isn’t manufacturing exactly the same product
Tenet Tax Daily March 15 2019
ITAT deleted Pepsico’s AMP adjustment due to absence of agreement with AE to spend on AMP
Tenet Tax Daily March 06 2019
ITAT benchmarked LIBOR and EURIBOR to determineALP of interest charged on sum advanced to AE
Tenet Tax Daily February 28 2019
Sum paid to NR for providing advisory by way of reviewing strategies and M&A options not to be held as FTS
Tenet Tax Daily February 19 2019