TaxBuzz | Eligibility of US based LLC to avail benefits under the India-USA DTAA

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 […]

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 […]