Specialized Investment Fund distribution now requires dedicated certification, while transitional recognition preserves existing qualified distributor...
Overlapping GST proceedings require Central and State authorities to designate one competent authority for coordinated adjudication of the same matter...
Composite healthcare supplies retain exemption when patient care is the contract's essential character, despite payment through an implementing agency...
Receipt of immovable property requires actual possession or enjoyment; redevelopment allotments exchanged for tenancy rights fall outside deemed incom...
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Payments to a UAE entity for advisory and consultative services were not fees for technical services because the services did not make available any technical know-how, process or methodology enabling independent future use by the recipient. In the absence of a specific FTS article in the India-UAE DTAA, domestic section 9(1)(vii) could not be imported to tax the remittance under the treaty. With no permanent establishment of the UAE entity in India, the income was treated as business profits under Article 7 and not taxable in India. A CBDT circular could not enlarge taxability contrary to the treaty, so the payer was not in default under sections 201(1) and 201(1A) and the demand was deleted.
Payments to a UAE entity for advisory and consultative services were not fees for technical services because the services did not make available any technical know-how, process or methodology enabling independent future use by the recipient. In the absence of a specific FTS article in the India-UAE DTAA, domestic section 9(1)(vii) could not be imported to tax the remittance under the treaty. With no permanent establishment of the UAE entity in India, the income was treated as business profits under Article 7 and not taxable in India. A CBDT circular could not enlarge taxability contrary to the treaty, so the payer was not in default under sections 201(1) and 201(1A) and the demand was deleted.
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