Home Highlights January 2014 Year 2014 This

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1. Valuation of imported goods - Inclusion of lump sum and periodical patent and technology know how fee paid - The Tribunal analyzed the provisions of Rule 10 (1) (c) of...

2. TDS u/s 195 - TDS on overseas payment - Annual Payment made to the international boards through affiliation with IBO, Cambridge etc. under the head authorization fee,...

3. Income accrued In India - 'Royalty' or 'Fees for Technical Services' under Section 9(l)(vi) and 9(l)(vii) - the payment made by SCB to assessee- company does not fall...

4. Disallowance of payments made for royalty and technical know-how received - Accepted Most appropriate method for benchmarking the manufacturing segment as TNNM -...

5. TDS disallowance u/s 40(a)(i) for non-deduction on overseas payments towards patent fees, reimbursement of official fees and professional fees, treating such payments as...

6. Valuation - The royalty and lump sum fees paid in relation to manufacture of goods in India cannot be padded on to the declared import value of the impugned goods.

7. The ITAT Ahmedabad addressed Transfer Pricing (TP) adjustments, focusing on royalty, management fees, and IT allocation costs. The tribunal upheld the use of the...

8. TDS u/s 195 not deducted on payment to Everest Global Inc. for software training services as source of income located outside India and payment made for services outside...

9. TP Adjustment on account of the Management fees and payment of R&D expenses - As regards, failure of the Assessee to provide service wise break-up of management fee, the...

10. Payment to overseas institution as fees for awarding the degrees, supplying books and course material – There is no transfer of any technical know-how or technical...

11. Nature of expenses on Technical know-how fee - such technical know-how was used for the purpose of manufacturing the existing items - held as revenue expenditure - HC

12. The assessee, a foreign company, earned network transportation fees from its Indian associated enterprise (AE), Damco India Private Limited (DIPL). The Assessing Officer...

13. Valuation - inclusion of value of technical know how fee or royalty paid - the Importer is permitted to purchase components from other parties also. There is no...

14. Valuation - technical know-how fee - royalty fee - There is no evidence that the burden of royalty is to be borne by the appellants. Same is therefore not includible in...

15. Assessable value - Royalties/licence fees were to be paid to the foreign supplier of the equipments - For application of Rule 9(1)(e) there had to be a finding that...