Tax Management India. Com
Law and Practice  :  Digital eBook
Research is most exciting & rewarding


  TMI - Tax Management India. Com
Follow us:
  Facebook   Twitter   Linkedin   Telegram
Income Tax - Highlights / Catch Notes

Home Highlights July 2012 Year 2012 This

Disallowance made of royalty paid by the assessee to CAMI USA ...

Income Tax

July 23, 2012

Disallowance made of royalty paid by the assessee to CAMI USA for distribution of software products in India - Once it is accepted that the ALP of the royalty is justified, there can be no reduction in the value thereof on account of the assessee's customers failing to pay the assessee for the product purchased by them from the assessee. - HC

View Source

 


 

You may also like:

  1. TDS - Distribution of software product - payment made by the assessee to nonresident companies would amount to royalty within the meaning of Article 12 of the DTAA -...

  2. The royalty paid by the appellant to their holding company in USA towards the that receipt and use of software does does not fall under the 'Intellectual Property...

  3. DTAA between India and USA - Royalty income - irrespective of the system of accounting, royalties are taxable on cash basis. - AT

  4. Disallowance of education cess on income tax and dividend distribution tax u/s 40(a)(ii) - Assessee has fairly conceded that as per amendment vide Finance Act, 2022...

  5. Accrual of income - Royalty - the distribution rights granted by the assessee to NGC India is only a commercial right / Broad Cast reproduction right and not copyright...

  6. Withholding Tax (TDS) u/s 195 - payment of distribution fees - treatment as Royalty / FTS - DAPE [Dependent Agent Permanent Establishment - the Assessee cannot be...

  7. TDS u/s 195 - taxability of the receipts of University of Texas, USA - there was neither any patent/copyright used by the assessee against which the royalty was paid nor...

  8. Capital or revenue expenses - Disallowance of royalty - if there is no sales, no royalty is payable by the assessee - held as revenue in nature - AT

  9. Royalty expenditure - Capital OR Revenue - assessee purchased distribution rights of the Punjabi film - As the AO has ignored the Board Circular No. 92 dated 18.9.1972...

  10. Disallowance of payments to related party u/s 40A(2)(b) - The ITAT observed that, from the working of corporate service charges for the financial year 2005-06, we find...

 

Quick Updates:Latest Updates