technical engineering

Use of Cash Profit / Sales and Cash Profit / Cost emphasized as an appropriate PLI for use of TNMM

In the case of Schefenacker Motherson Ltd v. ITO, ITA No. 4459/DEL/07 for AY 2003-04 and schefenacker Motherson Ltd v. DCIT, ITA No.4460/DEL/07 for AY 2004-05, the Delhi Bench of the Income-tax Appellate Tribunal (the Tribunal), held that cash profit on sales “CP/Sales” or cash profit on total cost excluding depreciation “CP/TCdep” can be adopted as an appropriate profit level indicator (PLI) under Transactional Net Margin Method (TNMM), to adjust for material d..
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Outright purchase of plant knowhow in the form of technical / engineering data, design, drawings is not royalty subject to withholding taxes

Himachal Pradesh High Court holds that Outright purchase of plant knowhow in the form of technical / engineering data, design, drawings etc. is not royalty / fee for technical service, subject to withholding taxes
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