Tax Management India. Com
Law and Practice  :  Digital eBook
Research is most exciting & rewarding
  TMI - Tax Management India. Com
Follow us:
  Facebook   Twitter   Linkedin   Telegram
Income Tax - Highlights / Catch Notes

Home Highlights May 2020 Year 2020 This

TP Adjustment - payment made to its AE towards Maintenance ...


Taxpayer Challenges TPO's Separate Treatment of Maintenance Services in Transfer Pricing for Software Licenses u/s 92C.

May 30, 2020

Case Laws     Income Tax     AT

TP Adjustment - payment made to its AE towards Maintenance services relating to software licenses - There is merit in the contentions of the assessee that the distribution of software licenses and their maintenance are inter-linked. - TPO was not justified in viewing maintenance services as separate from the distribution activity.

View Source

 


 

You may also like:

  1. Management, Maintenance or Repair Service - Software Services Agreement - repair and maintenance of software - stay granted - AT

  2. Classification of services - The activity undertaken by the applicant is waste treatment/processing of wet waste provided by GCC and maintenance of the designated Micro...

  3. The receipts towards repairs and maintenance services rendered by the assessee cannot be construed as "Fee for Technical Services" (FTS) u/s 9(1)(vii) of the Income Tax...

  4. The Appellate Tribunal reviewed a case involving Transfer Pricing (TP) Adjustment for management service fee paid to Associated Enterprises. It was held that the...

  5. The ITAT provided the following rulings: Regarding TP adjustment for comparable selection and treatment of IT support services as ITeS, the issue requires examination by...

  6. Classification of services - Maintenance and Repair service or otherwise - no repair or maintenance service has been rendered by the assessee and whatever repair service...

  7. Levy of Service Tax - maintenance security deposit - whether any service on this amount was provided or not - The respondent has not received any consideration for...

  8. Transfer pricing adjustments, selection of the most appropriate method (MAM), benchmarking approach (aggregation or segregation), factual rendering of services, arm's...

  9. Levy of Service Tax - Commercial or Industrial construction services provided to Railways - The provisions of Section 65A of Finance Act 1994 provides for classification...

  10. ITAT rejected the TPO's approach of aggregating all international transactions for transfer pricing analysis. The Tribunal found that the TPO improperly combined payment...

  11. Commercial Coaching or Training Services and Management, maintenance and repair services - training in Aircraft Maintenance Engineering - held as taxable services -...

  12. Management, Maintenance or Repair Services - amounts collected under the head 'backup power supply' - No service tax.

  13. The Appellate Tribunal (ITAT) considered a case involving Transfer Pricing (TP) Adjustment where the Transfer Pricing Officer (TPO) determined the Arm's Length Price...

  14. ITAT addressed transfer pricing adjustment regarding business support services between associated enterprises. TPO rejected assessee's TNMM method and entity-level...

  15. Rectification of register of members by deleting the transfer entry - transfer of shares - the action of challenging the validity of transfer deed dated December 22,...

 

Quick Updates:Latest Updates