Bombay High Court Upholds APA-Based Royalty Adjustment; Refunded Rs. 19.44 Crore Cannot Be Taxed as Income of Foreign AE

Bombay High Court Upholds APA-Based Royalty Adjustment; Refunded Rs. 19.44 Crore Cannot Be Taxed as Income of Foreign AE The […]

Interest Received by Indian Branch from Overseas Head Office of American Express Is Not Taxable on Principle of Mutuality: ITAT

Interest Received by Indian Branch from Overseas Head Office of American Express Is Not Taxable on Principle of Mutuality: ITAT […]

ITAT Mumbai Deletes Rs 6.49 Crore Addition And Accepts Revenue Sharing Between India and UK Offices

Cross-Border M&A Advisory Revenue Cannot Be Fully Attributed to Indian PE: ITAT The Income Tax Appellate Tribunal (ITAT) Mumbai deleted […]

ITAT Rejects Virtual Service PE Theory, Holds LinkedIn Profile Not Conclusive for PE Determination

ITAT Rejects Virtual Service PE Theory, Holds LinkedIn Profile Not Conclusive for PE Determination Case Details Case Reference ITA No. […]

ITAT Delhi Rejects Permanent Establishment Allegation Based Solely on LinkedIn Evidence

ITAT Delhi Rejects Permanent Establishment Allegation Based Solely on LinkedIn Evidence The ITAT Delhi has held in favour of IMAX […]

Delhi ITAT Denies Profit Attribution Without Existence of Permanent Establishment

Delhi ITAT Denies Profit Attribution Without Existence of Permanent Establishment The Delhi Bench of the Income Tax Appellate Tribunal (ITAT) […]

ITAT Says Software Licence Sales Not Taxable In Absence Of Permanent Establishment

ITAT Says Software Licence Sales Not Taxable In Absence Of Permanent Establishment Milestone Systems A/S, a Denmark-based company engaged in […]