Certificate-of-origin verification procedure governs preferential customs benefits; denial without retroactive verification was set aside with consequ...
Disciplinary Committee jurisdiction and mandatory investigation requirements invalidated cancellation of an insolvency professional's registration and...
Retention of seized property survives where recorded reasons support proceeds of crime, while stayed investigation periods are excluded from limitatio...
Specified income of Baddi Barotiwala Nalagarh Development Authority receives conditional tax exemption, retrospectively covering its designated assess...
Specified development authority income receives retrospective tax exemption, subject to non-commercial activity, unchanged income sources, and return-...
Unified Brand India framework introduces voluntary Trust Mark certification and funding support for export branding, packaging and global promotional ...
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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