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D R Shashank

Latest Posts by D R Shashank

Aggregation vs. Segregation Approach in Benchmarking International Transactions

September 25, 2024 1389 Views 0 comment Print

The ITAT remands BorgWarner’s case on TSS, BSS, and royalty benchmarking to TPO for re-determination, questioning the segregation approach used for international transactions.

TDS Obligations: Reimbursement of Expenses vs. Fee for Technical Services

September 25, 2024 2334 Views 0 comment Print

Delhi HC rules reimbursements to NRAEs not subject to TDS as “fees for technical services,” clarifying scope of Section 9(1)(vii) and TDS under Section 195.

U.S. LLCs with Separate Legal Identity Eligible for Treaty Benefits: Key crux of General Motors case

September 25, 2024 1857 Views 0 comment Print

Explore how LLCs qualify for India-US DTAA benefits, focusing on tax liability and resident status under Article 4 in the General Motors vs ACIT case.

Source State’s Right to Attribute Income to a PE Based on Global Income/Loss

September 21, 2024 1428 Views 0 comment Print

Delhi High Court clarifies taxability of profits attributed to a Permanent Establishment (PE) under the India-UAE DTAA, even when global losses are incurred.

Case Analysis of Tiger Global International III Holdings v. Authority for Advance Rulings (Income- Tax) & Ors.

August 30, 2024 3549 Views 0 comment Print

Tiger Global International III Holdings Vs Authority for Advance Rulings (Income- Tax) & Ors. (Delhi High Court) The Delhi High Court delivered a significant judgment in the case of Tiger Global International III Holdings v. The Authority for Advance Rulings (Income-Tax) & Ors., reaffirming the importance of the Tax Residency Certificate (TRC) in international tax […]

Integration of Financial Innovation & Capital Market: A Clarion Call

January 2, 2024 1068 Views 0 comment Print

This article delves into regulatory uniformity, addressing challenges and the role of harmonization in fostering a resilient financial ecosystem.

Changeability of Income Tax on Source of Incomes of Family Investment Funds (Company/LLP)

November 8, 2023 1497 Views 0 comment Print

Understand how Changeability of Income Tax affects Family Investment Funds (Company/LLP) in the IFSCA Fund Management Regulations. Learn how the set up of a FIF in IFSC’s can help you invest globally with a closer to the ground Indian approach.

Transfer Pricing Rules: Substantial Question of Law or Facts

October 23, 2023 1887 Views 0 comment Print

Explore landmark cases like SAP Labs vs. IT Officer, Evalueserve vs. Commissioner, and Softbrands vs. IT. Learn how the law and facts intersect in transfer pricing disputes.

Tax Implications on Stewardship Activities

October 23, 2023 5922 Views 0 comment Print

Understand what qualifies as ‘stewardship activities’ for taxation in India with the Supreme Court’s single-entity approach. Taxes on stewardship activities, Morgan Stanley & Co v India judgement explained

Harmonizing Income Tax and Customs Valuation: Key Insights

October 22, 2023 2097 Views 0 comment Print

Explore intricate relationship between income tax and customs valuation. Learn how these realms intersect, challenges they pose, and strategies for harmonization.

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