Plant set-up on lump sum/composite/ turnkey basis
In [2021] 432 ITR 338 (AAR) the assessee had set up a project office in India to set up a…
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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
intra-group services under scrutiny
The subject under consideration before advance ruling authority in [2021] 431 ITR 626 (AAR) correspond to whether the continued real…
......Read MoreSoftware payments- No TDS
The Supreme Court finally answered to the chequered history on the obligation to deduct tax on software payments from their…
......Read MoreInternal restructuring boom
Vide (2021] 431 ITR 87 the AAR confronted a scheme of internal restructuring involving a transaction of transfer of shares…
......Read MoreSoftware Payments and equalisation levy
The Delhi High Court in their latest in [2021] 431 ITR 136 (Del) held that the consideration received by the…
......Read MoreNo tax withholding on Export commission
The Kerala High Court in [2021] 17 ITR-OL 69 (Ker) read into the expanded scope of section 5(2) to the…
......Read MoreWhat is not royalty in nature could be FTS nature
The Bombay High Court in 304ITR201 in the context of a company in diamond market held that consideration received by…
......Read MoreTaxation of third world incomes
In Emmerich Jaegar v. CIT (2005)274ITR125 the assessee non-resident claimed benefit under an exception (exemption) provision of Article 14(2) under…
......Read MoreTax Residence abnormalities –UAE Resident
For the first time, the AAR in Mohsinally Alimohammed Rafik, In re (1995) 213ITR317 held a view that a UAE…
......Read MoreHeight of perversity
Pointing out more than one perversity in the findings of fact by the AO/DRP/Tribunal the Supreme Court in DIT (International…
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