Transaction value rejection requires reliable corroboration; refundable VAT is excluded and temporary registration does not defeat new-vehicle exempti...
Appellate jurisdiction remains available where a wrist-worn gold ornament cannot conclusively be characterised as imported baggage at the preliminary ...
Written complaint requirement bars cognizance on police reports for securities offences, while unsupported breach of trust and cheating allegations fa...
Risk-based postal import clearance standardises electronic assessment, document requests, duty realisation and delivery controls at Foreign Post Offic...
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Under Article 12 of the India-Netherlands DTAA, intra-group service and cost-recovery receipts were held not to be fees for technical services because the services did not satisfy the make available condition; the recipient was not shown to acquire technical knowledge, skill, know-how or processes for independent future use. The separate plea that the receipts were mere reimbursements or cost allocations was rejected following earlier years. Surcharge and cess beyond the treaty rate on royalty and fees for technical services were disallowed because the treaty caps tax at 10 per cent and Indian tax includes surcharge. Computation errors, interest under section 234B, TDS credit and refund adjustment issues were remitted for verification.
Under Article 12 of the India-Netherlands DTAA, intra-group service and cost-recovery receipts were held not to be fees for technical services because the services did not satisfy the make available condition; the recipient was not shown to acquire technical knowledge, skill, know-how or processes for independent future use. The separate plea that the receipts were mere reimbursements or cost allocations was rejected following earlier years. Surcharge and cess beyond the treaty rate on royalty and fees for technical services were disallowed because the treaty caps tax at 10 per cent and Indian tax includes surcharge. Computation errors, interest under section 234B, TDS credit and refund adjustment issues were remitted for verification.
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