Vicarious liability for dishonoured company cheques may extend to non-signatory directors where complaints contain foundational responsibility avermen...
Charitable registration turns on predominant purpose and genuine activities, while incidental fees and related-party rent require supporting adverse m...
MAT book-profit adjustments exclude disallowances for exempt-income expenditure and demerger expenditure unless expressly listed under the statutory c...
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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