Export 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…
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Today's
Wrong reopening ......Read More
Yesterday's In no way the AO has power to question arm’s length pricing in unrelated party transactions ......Read More
Yesterday's In no way the AO has power to question arm’s length pricing in unrelated party transactions ......Read More
DTAA 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…
......Read MoreCorporate guarantee
The Tribunal in [2021] 25 ITR (Trib)-OL 1 (ITAT[Ahm]) after admitting that in case of an associated enterprise the guarantee…
......Read MoreDTAA benefit cannot be declined for want of presentation of TRC… impossibility of performance case
The assessee who earned from employment abroad was declined exemption under article 15(1) of the India-Austria DTAA in (2020] 79…
......Read MoreTreaty shopping within framework of law
The AAR in [2021] 434 ITR 180 (AAR) is required to answer a question whether the capital gains on the…
......Read Morenon-resident commission agents qua source rule
Following Supreme Court decision in CIT v. TOSHOKU LTD. [1980] 125 ITR 525 and the source rule principle the Karnataka…
......Read MoreFTS ancillary clause under USA treaty
The AAR in [2021] 434 ITR 101 (AAR) dealt with range of service agreements between sister concerns to ascertain application…
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