Taxability of software sale by the US entity to Indian entities ...

Tribunal Rules on Software Sales Taxation, Arm's Length Compensation, and Misinterpretation of Agreements in India.

February 15, 2024

Case Laws Income Tax AT

Taxability of software sale by the US entity to Indian entities - Indian subsidiary is held as DAPE [Dependent Agent Permanent Establishment] of the assessee in India - when DAPE is remunerated at arm’s length - The Tribunal, following its previous rulings, found the assessment to misinterpret the distribution agreement and BAPA, holding that if the DAPE is remunerated at arm's length, no further addition can be made.

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Taxability of software sale by the US entity to Indian entities ...

Tribunal Rules on Software Sales Taxation, Arm's Length Compensation, and Misinterpretation of Agreements in India.

February 15, 2024

Case Laws Income Tax AT

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