Programme production and copyright assignment can be separately taxed when the agreement shows distinct production activity on behalf of the broadcast...
Transshipment permission for courier import goods granted subject to customs supervision, bond compliance, sealing, escort and destination acknowledgm...
Payments to a non-resident under a Production Sharing Contract were treated as taxable unless the claimed reimbursement was supported by item-wise expenditure particulars and, where necessary, a chargeable proportion determination under the withholding regime. The arm's length clause did not create a presumption that every reimbursement was non-taxable. Because the assessee had filed only a consolidated reimbursement claim without furnishing details or seeking determination of the chargeable portion, tax at source was required and liability under the deeming provisions was upheld. The alternative double taxation relief argument failed because, for the relevant years, relief applied only to agreements with foreign Governments, not the private consortium arrangement.
Payments to a non-resident under a Production Sharing Contract were treated as taxable unless the claimed reimbursement was supported by item-wise expenditure particulars and, where necessary, a chargeable proportion determination under the withholding regime. The arm's length clause did not create a presumption that every reimbursement was non-taxable. Because the assessee had filed only a consolidated reimbursement claim without furnishing details or seeking determination of the chargeable portion, tax at source was required and liability under the deeming provisions was upheld. The alternative double taxation relief argument failed because, for the relevant years, relief applied only to agreements with foreign Governments, not the private consortium arrangement.
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