During the years under consideration, it had deputed its pilots and cockpit crew to non-resident companies for training on flight simulators. The ITAT held that since hiring of simulator by itself has no purpose, fee paid for simulator is not royalty. Further, in absence of FTS article in India-UAE DTAA, it was to be treated […]
CIT v CA COMPUTER ASSOCIATES INDIA PVT LTD (2013) 351 ITR 69 (Bom)
It was held that the ALP should be determined as per the procedure prescribed. Any deviation from the prescribed procedure cannot be sustained. Facts The taxpayer was engaged in the business of licensing mainframe, midrange and system infrastructure software products of CA Management Inc. of the USA. The taxpayer had set-up a Technical Support Centre […]
PCIT VS. LUWA INDIA PVT. LTD. [TS-281-HC-2021 (KAR HC)-TP]
While exercising jurisdiction u/s 92CA(3), the TPO can only determine the ALP of an international transaction and cannot examine the allowability of the claim by applying the benefit test or the conditions as provided under Section 37(1) of the Act Facts The assessee, was engaged in the business of manufacturing textiles machines for textile manufacturers […]
TDS on AWS, Mail Chimp, Online Ads – URBAN LADDER HOME DÉCOR SOLUTIONS PVT. LTD [TS-773-ITAT-2021(Bang)]
The Assessment years involved are AY 2015-16, 2016-17 and 2017-18. The Assessee-Company is engaged in the business of dealing in home décor products and sells its products mainly through online marketing. The Assessee placed advertisements on the platform of Facebook, Ireland. The Assessee also used the bulk mail facility offered by M/s Rocket Science Group, […]
TAXATION OF CLOUD COMPUTING SERVICES UNDER INCOME TAX ACT
In today’s technology world, businesses require access to high end technology equipment like servers in order to host various services online. Due to this, requirement for these kinds of servers have increased tremendously, especially for e-commerce businesses. Owning/maintaining such servers and upkeep requires skilled manpower, which is a costly affair. So many e-commerce start-up companies […]