with a benefit and services provided to the AE under a
mutual agreement which was, although, not in writing, but such
arrangements could be proved ... instance/ behest of overseas AEs, nor was
there any mutual agreement or understanding or arrangement as to
allocation or contribution by the AE towards reimbursement
assessee share its technical plan the workscope is prepared with mutual
agreements and training is also provided as these services are of technical
nature ... task
As assessee make available technical plan, workscope were prepared by
mutual agreement the employees of Indian customers gain the technical
knowledge of detecting
erred in disregarding the
principles arrived for in the Mutual Agreement Procedure
('MAP') resolution arrived at between the Competent
Authorities of India ... above-mentioned revenues to
tax on the basis of erstwhile Mutual Agreement Procedure ('MAP')
10 ITA Nos. 2432 & 3717/Del/2023
Turner
erred in disregarding the
principles arrived for in the Mutual Agreement Procedure
('MAP') resolution arrived at between the Competent
Authorities of India ... above-mentioned revenues to
tax on the basis of erstwhile Mutual Agreement Procedure ('MAP')
10 ITA Nos. 2432 & 3717/Del/2023
Turner
Samsung India Electronics Pvt. Ltd., ... vs Acit, New Delhi on 4 October, 2019
IN THE
lump sum is to be revised twice a year by mutual agreement of the parties to reflect the volume of the services actually rendered ... agreement into four different transactions. Unless there was imperative need, which the revenue department is unable to grasp, these four agreements would not have been
Bellsonica in any
such law suits shall be decided by mutual agreement between Bellsonica and
Licenee if and when such a need arises.
(d) Bellsonica ... this
Agreement or upon refusal by Bellsonica or Licensee to agree to an extension
of this Agreement or to enter into a new agreement
income, losses or assets of such
enterprises and shall include a mutual agreement or
arrangement between two or more associated
enterprises for the allocation ... such nature of transaction described in the section will
also include mutual agreement and the arrangement
between the parties for allocation or apportionment
instance/ behest of
overseas AE, nor was there any mutual agreement or
understanding or arrangement as to allocation or contribution by
the AE towards reimbursement ... income, losses or assets of
such enterprises and shall include a mutual agreement or arrangement
between two or more associated enterprises for the allocation
connection with benefit and
services provided to the AE under a mutual agreement
though not in writing but if it can be proved from ... income, losses or assets of such
enterprises and shall include a mutual agreement
or arrangement between two or more associated
enterprises for the allocation
