SC held that Question as to what proportion of Profit is attributable to India is question of fact

Director of Income-tax v. Travelport Inc. – [2023] 149 taxmann.com 470 (SC) Facts: The taxpayers are engaged in the business of providing electronic global distribution services to Airlines through “Computerized Reservation System” (CRS). The taxpayers maintain and operate a Master Computer System consisting of several main frame computers and servers located in other countries, including […]

COMPARABLES FOR SOFTWARE DEVELOPMENT SERVICES FOR AY 2016-17

OLF (India) Software Pvt Ltd v ACIT [TS-456-ITAT-2021(Bang)-TP] [Judges: Shri Baskaran and Smt Beena Pillai] – The assessee is engaged in rendering software development services to AE. The assessee sought exclusion of Persistent Systems, Aspire Systems, Larsen and Toubro Infotech, Nihilent Technologies, Infosys Ltd, Thirdware Solution & Cybage Software on the ground that these companies […]

TP ADJUSTMENT FOR CORPORATE GUARANTEEE ONLY TO THE EXTENT LOAN FACILITY AVAILED – ASSOCIATED CAPSULES CASE

Associated Capsules Pvt. Ltd. v ACIT [2020] 121 taxmann.com 103 (Mumbai – Trib.) Facts The assessee is engaged in the business of manufacturing empty hard gelatine capsules. The assessee provided Corporate Guarantee of 2.4 million Euros (Equivalent to Rs. 15.19 crores) to its Croatian AE. The assessee did not make any adjustment on account of […]

Begin typing your search term above and press enter to search. Press ESC to cancel.

Back To Top