Origin Declaration authentication governs preferential tariff claims under India-UK CETA, requiring a validated reference number before import clearan...
Separate assessment orders for different years remain valid when distinct notices and hearing opportunities prevent prejudice from combined proceeding...
Defined public benefit can retain charitable character; registration renewal requires examining genuine activities and legal compliance, not surplus a...
Capital reduction is distinct from share buy-back, preventing buy-back tax; restructuring interest and related business deductions also survive scruti...
Receipts from SaaS-based product analytics services rendered to Indian customers were held not taxable as royalty or as fees for technical services/included services under the Act or the India-USA DTAA, because customers only availed services and did not acquire any right to use the assessee's infrastructure, software, or other assets for commercial exploitation. The Tribunal followed jurisdictional High Court and coordinate bench rulings, including Amazon Web Services, and deleted the addition for both assessment years. On TDS credit, the matter was remitted for verification, with directions to allow due credit and recompute interest and allied relief consequentially to the deletion of the substantive addition.
Receipts from SaaS-based product analytics services rendered to Indian customers were held not taxable as royalty or as fees for technical services/included services under the Act or the India-USA DTAA, because customers only availed services and did not acquire any right to use the assessee's infrastructure, software, or other assets for commercial exploitation. The Tribunal followed jurisdictional High Court and coordinate bench rulings, including Amazon Web Services, and deleted the addition for both assessment years. On TDS credit, the matter was remitted for verification, with directions to allow due credit and recompute interest and allied relief consequentially to the deletion of the substantive addition.
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