TP adjustment upheld as per Special Bench ruling in ...

TP adjustment upheld; tax treaty benefit denied; mirror ALP rejected; receipts taxable on receipt basis; software, services income non-taxable.

December 26, 2024

Case Laws Income Tax AT

TP adjustment upheld as per Special Bench ruling in Instrumentarium rejecting base erosion argument. Benefit of tax treaty against TP provisions rejected following earlier ITAT order. Mirror ALP principle rejected relying on Filtrex Technologies. Receipts taxable only on receipt basis per Ampacet Cyprus to be re-adjudicated. Software income treated as non-royalty and Global P&T services, HLPL receipts, L&T services income held as non-fees for technical services deleting respective additions following earlier ITAT orders.

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TP adjustment upheld as per Special Bench ruling in ...

TP adjustment upheld; tax treaty benefit denied; mirror ALP rejected; receipts taxable on receipt basis; software, services income non-taxable.

December 26, 2024

Case Laws Income Tax AT

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