Corporate TaxArticle·22 September 2026
Delhi HC says Indian Payer Alone Cannot Create Taxable Accrual for Non-Resident
By J the App
Executive Summary
The Delhi High Court quashed reassessment proceedings against Teva USA concerning payments arising from pharmaceutical marketing rights and a settlement governed by US arrangements. The Court held that the mere fact that Ranbaxy India made the payment from India could not constitute a universal source rule, particularly where the underlying rights, contractual dispute and commercial activity were situated outside India.
Domain | DT | Corporate Tax
The Position
For a non-resident, ...
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