By Shannon Khalkho This is Part II of a series on the transfer pricing issue of AMP expenses. It analyses the impact and implications of the shifts in judicial trends discussed in the last post. The combined effect of Sony Ericsson Mobile Communications India Pvt. … Continue reading The ‘AMP Expenses’ Dilemma: Can the Supreme Court Clear the Dust?

By Shannon A. Khalkho This is Part I of a series on the transfer pricing issue of AMP expenses. It traces the shifts in the judicial treatment of the same. Introduction The issue of Advertisement, Marketing and Promotion (AMP) expenses incurred by a domestic entity … Continue reading The ‘AMP Expenses’ Dilemma in Transfer Pricing

By Hitesh Kumar A Introduction This post throws light on whether payments for the utilisation and maintenance of a standard software would fall under the purview of ‘fees for technical services’ (FTS). FTS is a payment received for the ‘rendering’ (under the Income Tax Act) … Continue reading Case Review: Director of Income Tax v. AP Moller Maersk AS

By Siddarth P Chokkalingam This is Part II of a series on the concept of service PE. It discusses an alternate approach to understanding service PE. Introduction: In the previous post, I took cue from the e-Funds ruling to argue that viewing a service PE … Continue reading Service PE: Take 2

By Siddarth P Chokkalingam This is Part I of a series on the concept of service PE. It analyses the confusion inherent in the Supreme Court’s understanding of service PE. Introduction: A permanent establishment [PE] is a common feature of several bilateral treaties between countries … Continue reading Service PE: Confusions Galore