TP Adjustment - Addition as ‘Fees for Technical Services’ ...

Transfer Pricing Dispute Over Technical Services Fee Sent Back for Re-evaluation; Assessee Claims It's a Reimbursement.

September 16, 2023

Case Laws Income Tax AT

TP Adjustment - Addition as ‘Fees for Technical Services’ ignoring the assessee’s contention that it was purely reimbursement received for Construction and Management Expenses - Matter restored back for fresh adjudication - AT

View Source

← Previous Next →

TP Adjustment - Addition as ‘Fees for Technical Services’ ...

Transfer Pricing Dispute Over Technical Services Fee Sent Back for Re-evaluation; Assessee Claims It's a Reimbursement.

September 16, 2023

Case Laws Income Tax AT

You may also like:

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

The assessee's income received from Indian customers as Fee for Technical Services (FTS)/Fee for Included Services (FIS) u/s 9(1)(vii) of the Act and Article 12(4) of...

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...

Corporate guarantee - fee for technical services (FTS) under article 13 of the India France DTAA and section 9(1)(vii) - services of corporate guarantee by the assessee...

Cenvat Credit - input services - services of empty containers sent back to the yard - credit allowed - AT

Fee for technical services is for the services rendered by the assessee and service tax collected by the assessee from the recipient of services on such fee would not...

Income deemed to accrue or arise in India - treatment of "Commission income" and receipts from "Subscription fee" - Assessee in publishing business receiving...

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...

The Income Tax Appellate Tribunal held that the export commission paid by the assessee to foreign agents in Korea and Indonesia for sales, marketing, and customer...

The assessee, incorporated under Canadian laws, rendered pre-clinical laboratory services to Indian customers in the pharmaceutical, medical device, and biotechnology...

TP adjustment on account of payment of overseas support fee - The assessee has its head office outside India and the decision, on the basis of which the assessee gets...

Taxability of receipts as 'fees for included services' under the India-USA Double Taxation Avoidance Agreement (DTAA). The key points are: The Assessing Officer (AO)...

TDS u/s 195 - professional services - Fees for Technical Services (FTS) - the definition of “Fees for Technical Services” has to be given a restrictive meaning similar...

The assessee received amounts from Indian customers for supplying software updates, patches, and on-call support services. The issue pertained to taxability of these...

The key points in the legal document are: Software licensing amounts do not qualify as Fees for Included Services under Article 12(4)(b) of the India-US DTAA, as the...

Quick Updates: