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Key points



Direct Taxes Page 2-7 Recent Decisions Outsourcing of services by US company to its Indian group company does not constitute PE in India Interest income and import entitlement sale consideration are eligible for tax holiday Price quotes from private databases acceptable for determining arm’s length price AAR shall not admit application if the proposed transaction is a mere intention.

Contact Mr. C.S. Mathur Telephone: +91 11 47 10 22 00 Email: [email protected] Ms. Saskia Bonenberger Telephone: +91 11 47 10 33 88 Email: [email protected] WTS India Private Limited 1-H, Vandhna 11, Tolstoy Marg New Delhi - 110 001. India www.wts.co.in

Recent Notifications Disallowance of expenditure incurred in relation to exempt income to apply even in the absence of exempt income in a particular year







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Indirect Tax Page 7-9 Amendment in the Notification No. 25/2012- Service tax dated 20-062012 Reverse Charge Liability paid by the Service Provider, should not be demanded again from Service Recipient Amendment in CENVAT Credit Rules, 2004 referred to as the CENVAT Credit (Third Amendment) Rules, 2014 Foreign Exchange Management Act Page 9-10 Third party payments for export/import transactions Policy on foreign investment in the Insurance Sector Important dates to remember Page 11

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Direct Taxes Recent Decisions International Taxation I. Outsourcing of services by US company to its Indian group company does not constitute PE in India In a recent judgment in the case of Director of Income-tax Vs E Funds IT Solution, the High Court of Delhi has held that outsourcing of services by US company to its Indian group company does not constitute Permanent Establishment in India as the assessee has no ‘right to use’ over the premises of the Indian company and the Indian company also was not its Agency PE as it did not participate in the negotiation of contracts with the third parties by the assessee. The High Court further held that the employees of the assessee who were working for the Indian company will not constitute its Service PE in India, as the same were not rendering any service in India on behalf of the assessee. e-Funds Corporation and e-Funds IT Solutions Group Inc. (“the assessee”) were companies incorporated in USA and were engaged in the business of electronic payments, ATM management services, decision support and risk management. E-Fund International India Private Limited (“e-fund India”), an Indian subsidiary of the Group, supported the assessee as its back office and also carried out data entry operations in respect of the above businesses of the assessee. e-Fund India was providing information and details to the assessee for the purpose of entering into contracts with third parties. Such contracts were also performed fully or partly by e-Fund India as an assignee or sub-contractor. The Revenue authorities contended that the assessee had a taxable presence in India under the Income tax Act, 1961 (“Act”) by way of business connection as well as PE under Article 5 of the India-USA DTAA and accordingly their income is attributable and taxable in India. The Tribunal upheld the existence of PE in India. However the Tribunal did not agree with the method of attribution adopted by the Revenue authorities in estimating profits attributable to the PE. On appeal by the assessee and the Revenue authorities, the High Court held that the existence of a subsidiary does not, by itself, constitute that subsidiary a PE of its parent, until the opposite is proved. It is a general legal principle that a subsidiary constitutes an independent legal entity for the purpose of taxation. The High Court held that the factors considered by the Revenue authorities for contending that the assessee had a PE in India such as: (i) The assessee and e-Fund India were closely connected; (ii) e-Fund India provided services to and was dependent Page 2 of 11

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on the assessees for its earnings; (iii) e-Fund India did not bear sufficient risk; (iv) intangible software was provided by assessees to e-Fund free of cost, and (v) assessees were subcontracting work/services to India, with an intent and purpose to save costs and to increase profitability are not relevant in deciding whether the assessees had a PE in India. As regards existence of fixed place PE, Service PE and Agency PE, the High Court held as under: Fixed Place PE - The assessees did not have any assets or a licensed office as their presence in India. The fact that the e-Fund India provides various services to the assessees and was dependent for its earning on the two assessees was not the relevant test to determine and decide location PE. The fact that e-Fund India was remunerated on a cost plus mark-up basis, or the allegation that it does not bear sufficient risk, is irrelevant in determining the existence of fixed place PE. Further, assignment or subcontract of an agreement to e-Funds India is also not a factor which is to be considered to determine existence of fixed place PE. It was observed by the High court that there was no evidence that the assessees had the ‘right to use’ or ‘disposal right’ over the premises of the Indian affiliate. Hence, even though the Indian affiliate was carrying on core activities for the assessees, it would not constitute a Fixed place PE of the assessees in India. Service PE- The High Court observed that to establish a Service PE of the assessee in India, the assessee must furnish services through employees or other personnel within India and the employees and other personnel must be of the assessee. The High court held that if the employees provide stewardship function, no PE exists for the foreign company. On the facts of the case, the High court observed that none of the employees of the assessee had visited India even for a short period. Even the two employees of the assessee who were transferred to e-Fund India were working for the Indian company and their entire expenditure was also borne by the Indian company. Hence they were not rendering any services in India on behalf of the assessee. The High Court further observed that the employees of e-Fund India were de-facto and de-jure employed by the Indian company and hence were not to be considered as employees of the assessee. Agency PE - The High Court observed that a subsidiary by itself cannot be considered to be a dependent agent of the parent. However, a subsidiary may become dependent if it satisfies the tests provided in the DTAA for creation of an Agency PE. As per the DTAA, an Agency PE is created, when a dependent agent who has and habitually exercises an authority to conclude contracts on behalf of the principal or habitually maintains stock of goods or merchandise from which he regularly delivers goods or merchandise on behalf of the principal or habitually secures orders almost wholly or wholly for the principal. The High Court observed that although e-Funds India was engaged in providing inputs and information to the assessee to enable them to enter into contracts which were subPage 3 of 11

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contracted to it, it does not mean that e-Fund India had participated in the negotiations of the assessee with the third parties. It thus held that e-Fund India does not constitute an Agency PE of the assessee as it was not authorized to conclude contracts on behalf of the assessee and did not maintain any stock or merchandise or secure orders on behalf of the assessee. In view of the above, no PE of the assessee was found to exist in India and therefore no profits were held to be taxable in India. Domestic Taxation I. Interest income and import entitlement sale consideration are eligible for tax holiday In a decision in the case of CIT Vs Motorola India Electronics (P) Ltd (ITA No. 428 and 447 of 2007), the High Court of Karnataka has held that the interest received on fixed deposits and consideration received from sale of import entitlement are eligible for benefit under Section 10B of the Income-tax Act, 1961 (“Act”), since there is a direct nexus between such income and the business of the undertaking. The assessee was a 100% percent Export Oriented Unit engaged in the export of software, the income of which was entitled to deduction in terms of Sections 10A and 10B of the Act. The assessee company had certain outstanding External Commercial Borrowings obtained in earlier years. Whilst the assessee had the capability of repayment of the same out the surplus profits generated from export business, it was permitted to repay only a small part, owing to exchange control restrictions. The resultant surplus was invested in certain accounts and fixed deposits, which yielded interest income. Moreover, the assessee did also receive certain consideration towards sale of import entitlements. The assessee claimed that such interest earned and the profit on sale of import entitlements must be characterized as ‘income from business’ and the same is therefore entitled for deduction under section 10B of the Act. During the course of assessment proceedings, the deduction on the aforesaid amounts was denied by the Assessing Officer on the premise that the same does not constitute ‘profits derived from export’. On further appeal, the Commissioner (Appeals) upheld the order of the Assessing Officer. However, the Tribunal held that the assessee would be entitled to deduction on such amounts. On appeal before the High Court, it was observed by the High Court that for the purpose of deduction under section 10B on the profits derived from export, section 10B(4) explains that the ‘profits derived from export’, shall be the amount which bears to the profits of the business of the undertaking’, the same proportion that the export turnover bears to the total turnover. In other words, the expression ‘profits and gains derived from export of articles’, has a different connotation as regards the expression ‘income derived from the profits of the business of the undertaking’.

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The High Court went on to observe that the profits of the business of the undertaking includes the profits and gains from export of articles, as well as all other incidental income derived from the business of the undertaking. In view thereof, it was held that the assessee was entitled to deduction under Section 10B(4) of the Act, with respect to the interest income and sale of import entitlements. Transfer Pricing I. Price quotes from private databases acceptable for determining arm’s length price In a recent judgement in the case of Tilda Riceland Pvt. Ltd. Vs. ACIT, the Income Tax Appellate Tribunal, Delhi Bench (“the Tribunal”) have held that the databases maintained by private entities are covered under Rule 10 D(3) of the Income -tax Rules, 1961 (“Rules”) and are acceptable as supporting documents for determining arm’s length price of the international transactions with associated enterprises. Tilda Riceland Pvt. Ltd. (“the assessee”) was an exporter of brown basmati rice and milled basmati rice in European Union, United States and Middle Eastern countries. The price charged by the assessee from its AEs was based upon the market trends. To benchmark the price charged from its AEs, the assessee had relied upon rates prevailing in the international market as reported in the database ‘Daily Export Port DataApril 2007 to March 2008’, compiled by TIPS Software Services Pvt. Ltd. Mumbai (“TIPS”) based on public data maintained by the customs department at various ports. The data maintained by TIPS provided quantum, price, date, quantity and the type of rice exported by parties in India to parties in European Union, Middle Eastern countries and North America. The assessee applied Comparable Uncontrolled Price (“CUP”) method to justify arm’s length price of international transactions, based on the above database. The Transfer Pricing Officer (“TPO”) rejected the comparable price data and CUP method applied by the assessee. The TPO held that the prices compiled by TIPS are quotes and as such, are not covered within the provisions of Rule 10D(3) as acceptable supporting documents to justify arm’s length price. Further, as the data relating to rice compiled by TIPS was for various brands of basmati/ non basmati rice, the TPO was of the view that such “brand” of rice cannot be quantified for adjustment. As such, the TPO concluded that since the characteristics of rice vary specially because of the brand name associated with each of various varieties of rice, in such a situation, economic adjustments cannot bring on parity between the controlled and uncontrolled transactions. The assessee raised objections before Dispute Resolution Panel against the order of TPO, which were rejected. On subsequent appeal, the Tribunal held that the view of the TPO that databases compiled by private entities are not included in rule 10D(3) and as such, cannot be relied upon by the assessee, is erroneous. The Tribunal held that Rule 10D(3) is only illustrative Page 5 of 11

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in nature and merely describes the information required to be maintained by the assessee under section 92D. Further, the Tribunal held that although the application of CUP Method requires close examination of product comparability, as a price may be materially influenced by differences between the goods in the controlled and uncontrolled transactions, but product comparability does not require the comparables to be exactly the same. Also, the generic goods, even under different brand names, do not cease to be comparable with each other unless the impact of brand or other intangibles is so substantial that it distorts the comparison altogether. Moreover, the minor variations in prices of generic goods are adequately taken care of by average in the case of large size of comparables. With respect to the manner of application of CUP method by assessee, the Tribunal held that under CUP method, the arm’s length price of the transactions with the AEs cannot be determined by comparing average export price by the assessee to its AEs with the average uncontrolled export price. While averaging is permissible for the uncontrolled comparable transactions, however, each international transaction is to be taken on standalone basis. Also, the CUP method does not allow exclusion of high priced sale instances unless such high prices could be explained by differences of product or commercial terms. Advance Ruling I. AAR shall not admit application if the proposed transaction is a mere intention. The Authority for Advance Ruling (“AAR”), in a recent ruling of Trade Circle Enterprises LLC (2014) 42 taxmann.com 287, has held that an application before it may be admitted only if it is a ‘transaction’ or a ‘proposed transaction’ and not a mere intention. The AAR held that the subject entities, between whom the transaction is proposed, must exist in reality. In the instant case, the applicant proposed to set up a wholly owned subsidiary in India in terms of the Foreign Direct Investment regulations. It was also proposed that the said subsidiary, in turn, would form a consortium with an Indian company, by way of a partnership firm, in pursuance of an infrastructure project. The applicant sought a ruling from the AAR on the aspect of availability of deduction under Section 80-IA(4) of the Act, with regard to such partnership firm. The AAR held that in order to come within the scope of section 245N of the Act, there has to be either a ‘transaction’ undertaken or ‘proposed transaction’ to be undertaken by the non-resident applicant, which was not the case with the present application. The AAR observed that the expressions ‘Transaction’ or ‘proposed transaction’ are not the same as a mere intention. Accordingly, the AAR held that in the instant case, the subsidiary as well as partnership firm must exist in reality, for the question to be brought within the ambit of Section 245N Page 6 of 11

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of the Act. Mere intention will not be covered by the same. In view thereof, the instant application was rejected by the AAR. Recent Notifications I. Disallowance of expenditure incurred in relation to exempt income to apply even in the absence of exempt income in a particular year The Central Board of Direct Taxes (“CBDT”) vide its circular number 5/2014 dated February 11, 2014, has clarified that disallowance under Section 14A of the Act read with Rule 8D of the Income-tax Rules, 1962 can be made even where a taxpayer, in a particular year, has not earned any exempt income. The CBDT, placing reliance on the Circular no 14/2001, has stated that the legislative intent of introduction of Section 14A of the Act is to allow expenses which are relatable to the earning of the taxable income, and therefore, all such expenses which are relatable to earning of exempt income are required to be disallowed, irrespective of the fact, whether any such exempt income has been earned during the relevant financial year or not. The Circular has further stated that the Section 14A uses the expression ‘income under the Act’ instead of ‘income of the year’ to provide that the exempt income should not necessarily be included in the total income of the financial year under consideration. It is mentioned that the aspect of incidence of Section 14A in the absence of exempt income in a particular year, has always been a contentious issue. Whilst in the case of Cheminvest [2009] 121 ITD 318 (DELHI)(SB), the Special Bench of Delhi Tribunal held that disallowance shall apply and it is immaterial whether exempt income has been earned in the previous year, a contrary view has been adopted by the Bombay High Court in the case of Delite Enterprises (ITA no. 110 of 2009).

Indirect Tax Service tax Recent Notification I.

Amendment in the Notification No. 25/2012- Service tax dated 20-06-2012

The department vide Notification No.04/2014-Service Tax dated February 17, 2014 has made some additions to the Notification No. 25/2012-Service Tax (Mega exemption) as under: 

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Entry 2A is inserted for ‘Services provided by cord blood banks by way of preservations of stem cells or any other service in relation to such preservations’ and

# 2. February, 2014 

Entry 40 is inserted for ‘Services by way of loading, unloading, packing, storage or warehousing of rice’.

Recent Decision I. Reverse Charge Liability paid by the Service Provider, should not be demanded again from Service Recipient In the case of Umasons Auto Compo Pvt Ltd Versus Commissioner of Central Excise & Customs, it was held by the Hon’ble Tribunal that once the amount of Service Tax is accepted by the Revenue from the provider of GTA service, it cannot be demanded again from the recipient of the GTA service. In the present case, M/s Umasons Auto Compo Pvt. Ltd. (The Appellant) was receiving Goods Transport Agency (“GTA”) service from GTA service provider for which they were paying Service Tax to the provider of GTA service. The provider of GTA service has deposited the amount of Service Tax to the Department, which was duly accepted by the Department and subsequently the Appellant had availed the Cenvat credit for the amount of Service Tax so paid to the provider of GTA service. The Assessing Officer raised demand for service tax on the Appellant in regards to GTA service availed by him and contended that the appellant who is the recipient of GTA service is liable to pay service tax under the reverse charge mechanism in terms of section 68(2) of the Finance Act, 1944. The Appellant filed the appeal before the Commissioner of Customs & Central Excise (Appeals) who upheld the adjudication order and confirmed the service tax demand. The Appellant thereafter moved this appeal before the Hon’ble Mumbai CESTAT. The Hon’ble CESTAT held that once the amount of service tax is accepted by the Revenue from the provider of GTA service the same cannot be demanded again from the recipient of GTA service. Hence the impugned order was set aside and in favour of the Appellant. [Source: Umasons Auto Compo Pvt Ltd Versus Commissioner Of Central Excise & Customs, 2014 (2) Tmi 100 – CESTAT Mumbai] Central Excise Recent Notification I. Amendment in CENVAT Credit Rules, 2004 referred to as the CENVAT Credit (Third Amendment) Rules, 2014 The department vide Notification No. 05/2014-Central Excise (N.T) dated February 24, 2014 has made some amendments in CENVAT Credit Rules, 2004 which shall be called Page 8 of 11

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the CENVAT Credit (Third Amendment) Rules, 2014 and shall come into force on the 1st day of April, 2014. Provisions of Rule 7 of the CENVAT Credit Rules, 2004 are: Rule 7(b) states that, credit of service tax attributable to services ‘used in a unit’ exclusively engaged in manufacture of exempted goods or providing of exempted services shall not be distributed. In the above sub-clause, the words ‘used in a unit’ is substituted by the words ‘used by one or more units’. Rule 7(c) states that, credit of service attributable to service used ‘wholly in a unit’ shall be distributed only to that unit. In the above sub-clause, the words ‘wholly used in a unit’ is substituted by the words ‘wholly used by a unit’. Rule 7(d) states that, ‘credit of service tax attributable to service used in more than one unit shall be distributed pro rata on the basis of the turnover during the relevant period of the concerned unit to the sum total of the turnover of all the units to which the service relates during the same period’. The above sub clause has been substituted by the words, ‘credit of service tax attributable to service used by more than one unit shall be distributed pro rata on the basis of the turnover of such units during the relevant period to the total turnover of all its units, which are operational in the current year during the said relevant period’. Explanation 3 has also been substituted where ‘relevant period’ shall be: 

If the assessee has turnover in the financial year preceding to the year during which credit is to be distributed for month or quarter, as the case may be, the said financial year or



If the assessee does not have turnover for some or all the units in the preceding financial year, the last quarter for which details of turnover of all the units are available, previous to the month or quarter for which credit is to be distributed.

Foreign Exchange Management Act I. Third party payments for export/import transactions As per the existing Foreign Exchange Management Act, 1999 (‘FEMA’) guidelines, Authorised Dealer Category-I Banks (‘AD Banks’) are allowed to make third party payments for export of goods and software and import of goods, subject to certain conditions inter alia including that a firm irrevocable order backed by a tripartite agreement should be in place. Page 9 of 11

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However, in view of difficulties faced by exporters/ importers in meeting the aforementioned condition, it has been decided by Reserve Bank of India (‘RBI’) that the said condition may not be insisted upon in a case where the documentary evidence for circumstances leading to third party payments / name of the third party being mentioned in the irrevocable order/ invoice has been produced, subject to the following conditions: 

AD bank should be satisfied with the bona-fides of the transaction and export documents, such as, invoice / Foreign Inward Remittance Certificate (FIRC).



AD Bank should consider the Financial Action Task Force (FATF) statements while handling such transaction

Further, the limit of USD 100,000/- eligible for third party payment for import of goods, has been withdrawn. [Source: A.P. (DIR Series) Circular No.100 dated February 4, 2014] II.

Policy on foreign investment in the Insurance Sector

As per the Consolidated Foreign Direct Investment (‘FDI’) Policy (effective from April 5, 2013), FDI in Insurance Sector is permitted up to 26% under the automatic route, subject to the following conditions: 

FDI in the Insurance Sector, as prescribed in the Insurance Act, 1938 is allowed under the automatic route.



The overseas companies bringing FDI would be required to obtain the necessary license from Insurance Regulatory & Development Authority (‘IRDA’) for undertaking insurance activities.

The government has clarified that for the purpose of 'Sector/Activities' under FDI Policy, Insurance sector includes Insurance Company, Insurance Brokers, Third Party administrators, Surveyors and loss assessors. It has also been expressly provided that the 26% cap for foreign investment includes FDI, FII and NRI investment. [Source: Press Note 2 (2014 Series) dated February 4, 2014]

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Important dates to remember Topics Deposit of TDS for the month March, 2014 Deposit of Service Tax for Companies for the month of March, 2014

Due by April 30, 2014 March 31, 2014

Publisher WTS India Private Limited www.wts.co.in Author WTS India Private Limited 1-H, Vandhna 11, Tolstoy Marg New Delhi - 110 001 India Disclaimer: This Newsletter is for client circulation only. The contents of this document are for informational purposes only and do not constitute ‘professional advice’. The contents are intended but not guaranteed to be correct and WTS India P Ltd. disclaims all liability to any person for any loss or damage caused by errors/omissions whether arising from negligence, accident or any other cause.

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