We are pleased to share with you a copy of our in-house publication – “TaxBuzz”. In this edition, we have analyzed the recent decision of the Income-tax Appellate Tribunal in the case of General Motors Company USA, affirming the eligibility of US based Limited Liability Companies to avail benefits under the India-USA Double Taxation Avoidance […]
Category : TaxBuzz
TaxBuzz | Taxability of Receipts as FTS – Illuminating Findings on ‘Make Available’ & ‘Source Rule’
We are pleased to share with you a copy of our in-house publication – “TaxBuzz”. In this edition, we have analysed the recent judgment in International Management Group (UK) Ltd, wherein the Delhi High Court has examined the taxability of receipts of a UK resident taxpayer towards advisory and managerial services as Fees for Technical […]
Taxbuzz | Failure to follow mandatory provisions of section 144C – Whether fatal to assessment?
We are pleased to share with you a copy of our in-house publication – “TaxBuzz”, wherein we have analysed the recent judgment of the Delhi High Court in Sumitomo Corporation India (P) Ltd and other connected matters. The High Court has settled the controversy regarding the validity of final assessment order passed in the case […]
Education to be understood bearing in mind the changing times and the march of technology
We are pleased to share with you a copy of our in-house publication – “TaxBuzz”, wherein we have analysed the recent ruling of the Delhi High Court in NIIT Foundation. The High Court has, in the said ruling, adopting a pragmatic approach, interpreted the meaning and scope of “education” under section 2(15) of the Income […]
Taxbuzz – Section 148 Directions in Ashish Agarwal not universally applicable
We are pleased to share with you a copy of our in-house publication – “TaxBuzz”, wherein we have analysed the recent ruling of the Delhi High Court in Anindita Sengupta. The High Court in the said ruling, has delved into aspects relating to applicability of directions issued by Hon’ble Supreme Court in Ashish Agarwal under […]
Taxbuzz | Royalty paid on inter-company sales not at Arm’s Length
Payment of royalty on the sales made to the associated enterprise has always been disputed by the Indian Transfer Pricing department as not satisfying the arm’s length test. In a recent ruling[1], the Hon’ble Delhi Bench of Tribunal was pleased to delete the transfer pricing adjustment made in respect of payment of royalty on invoices […]