Clean slate principle extinguishes uncrystallised operational claims and bars continuation of pending recovery and arbitral proceedings after plan app...
Works contract classification governs composite layout-development contracts where VAT-paid goods are transferred alongside construction and infrastru...
Web hosting receipts are described as consideration for availing standard hosting facilities, not for use or right to use equipment, because the server space, connectivity and infrastructure remained under the provider's possession and control. The text also states that web hosting did not make available technical knowledge, skill, know-how or process, so it did not fall within fees for technical services under the India-USA DTAA. It further records that a unilateral domestic-law expansion of royalty cannot enlarge the narrower treaty definition, and the treaty prevails where more beneficial. On that basis, the receipts were treated as not taxable in India as royalty or FTS.
Web hosting receipts are described as consideration for availing standard hosting facilities, not for use or right to use equipment, because the server space, connectivity and infrastructure remained under the provider's possession and control. The text also states that web hosting did not make available technical knowledge, skill, know-how or process, so it did not fall within fees for technical services under the India-USA DTAA. It further records that a unilateral domestic-law expansion of royalty cannot enlarge the narrower treaty definition, and the treaty prevails where more beneficial. On that basis, the receipts were treated as not taxable in India as royalty or FTS.
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