Problematic situation
In the PepsiCo case @(2023] 30 ITR (Trib)-OL 1 (ITAT[Del]) the subject matter of appeal was essentially covered by the previous…
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Today's
Budget 2023 Interest free borrowing transactions now taxable ......Read More
Yesterday's Membership/Entrance fee receipts are tax exempt——department slp dismissed by Supreme Court ......Read More
Yesterday's Membership/Entrance fee receipts are tax exempt——department slp dismissed by Supreme Court ......Read More
No TDS on Export commission
Finally in a decision rendered by the Supreme Court in Vedanta ( Bby) and MATRIX CLOTHING PVT. LTD. (Del) case [2022] 448 ITR…
......Read MorePayments for training not liable to withholding
The Tribunal in [2022] 99 ITR (Trib) 607 (ITAT[Bang]) held that training expenses remain out of the purview of definition of “fee for…
......Read MoreIndustrial royalty payments
By the Pune bench decision in 2022] 99 ITR (Trib) 585 (ITAT[Pune])consideration payable for use of the information and communications technology infrastructure set…
......Read Morelower rate advantage under tax treaty in 197 applications
In making application u/s 197 a non resident can take benefit of DTAA as well as protocols issued for a…
......Read MoreExport Commission to non resident director held chargeable at PE rate
Normally export commission is not chargeable to tax in india unless services are technical or specialised in nature and go…
......Read MoreDTAA advantage for Interest incomes
Earnings from NRE account deposits are exempt from tax to certain class of individuals having non-residents or RNOR status under…
......Read MorePayment for use of facilities or technologies or infrastructure
The Bangalore ITAT in 28ITR(Trib) -OL 38 held that mere use of a facility is neither a payment for technical…
......Read MoreTPO crossing lines
In the Nike case reported at (2022] 27 ITR (Trib)-OL 322 (ITAT[Bang] the Transfer Pricing Officer took the view that the…
......Read MoreSection 197 arbitrary order
The non resident company operating in international air traffic and enjoying treaty benefits having no taxable income sought a certificate…
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