Mumbai ITAT holds that
taxability of Rs. 150 cr. received by assessee-company (part of the Mckinsey
Group based in US) in India during AYs 2011-12 and AY 2012-13 shall be
determined as per the MAP settlement for earlier years; Notes that as per the
terms of MAP settlement for AYs 2008-09 to 2009-10, it was agreed that payment
for providing various consultancy services (including Knowledge Pool Charges,
Borrowed Service Charges, Firm Committee Pool Charge, Regional Corporate
Finance Charges etc.) to its AE shall not be taxable in India as '
Royalty ' or ' Fees for Included Service (‘FIS’) '; ITAT rejects Revenue’s
stand that the MAP settlement being year-specific, cannot be made applicable to
subject assessment years; Notes that the MAP settlement is with respect to
amount paid by Mckinsey India to other Mckinsey entities in USA; Relies on
co-ordinate bench rulings in assessee’s own case and in case of its group
companies which accepted for applying the MAP terms of earlier years:ITAT
Subscribe to:
Post Comments (Atom)
Taxation of Intangible assets acquired through business restructuring.
1. Background 1.1 When a company aims to acquire another company's business through amalgamation or demerger, assets or ...
-
A new website launched for TDS related matters www.tdscpc.gov.in TRACES – T DS R econciliation A nalysis and C orrection E nabling S yste...
-
LEASE-DEED (A brief Introduction) Lease defined. A lease of immovable property is a transfer of a right to enjoy such property, mad...
-
Particulars in Part 1 and Part 2 of Step-2 of registration form are required to be exactly the same as reported in the TDS statement. Plea...
-
Introduction It's important for taxpayers to have a clear understanding of the available allowances and deductions, as they can grea...
-
· Mumbai ITAT in the case of Mukesh Harilal Mehta held that Exemption U/S 54 cannot be denied merely due to mistake by the developer.
-
Earlier this year, the Mauritius Government approved the amendment to the India – Mauritius tax treaty, aligning it with the proposal of th...
-
Slump sale is transfer of one or more business undertakings for a lump sum consideration, without assigning individual values to the each...
-
An eminent concern within the GST framework pertains to the entitlement of Input Tax Credit (ITC) concerning expenditures associated with In...
-
Introduction The law relating to companies is laid down in Companies Act, 2013 and the rules made thereunder and t...
-
This Tax Alert summarizes a recent judgement of the Delhi High Court (HC) [1] dealing with the issue of denial of input tax credit (ITC) ...
No comments:
Post a Comment