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Make-available condition excludes standard SaaS subscription receipts where customers receive no independently usable technical knowledge after subscr...
Receipts from feeder vessels and slot-hire arrangements were held to have a direct and integral nexus with the assessee's shipping business in international traffic, so they fell within Article 8 of the India-Germany DTAA and could not be separately taxed under section 44B; the addition on those receipts was deleted. The Tribunal did not decide the short TDS credit claim on merits and remitted it to the Assessing Officer for factual verification against the income offered and corresponding tax deducted, with a fresh decision after hearing the assessee.
Receipts from feeder vessels and slot-hire arrangements were held to have a direct and integral nexus with the assessee's shipping business in international traffic, so they fell within Article 8 of the India-Germany DTAA and could not be separately taxed under section 44B; the addition on those receipts was deleted. The Tribunal did not decide the short TDS credit claim on merits and remitted it to the Assessing Officer for factual verification against the income offered and corresponding tax deducted, with a fresh decision after hearing the assessee.
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