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...
Short deduction of tax at source did not warrant disallowance under section 40(a)(ia), and the related royalty-characterisation questions were treated as academic. Corporate guarantee commission was upheld at 0.5% because a corporate guarantee to an associated enterprise is not comparable to a bank guarantee, so no substantial question of law arose. On section 14A, where the assessee's own and other non-interest-bearing funds exceeded tax-free investments, a presumption arose that the investments came from interest-free funds, defeating interest disallowance under Rule 8D(2)(ii). Only the re-framed question under section 14A read with Rule 8D(2)(iii) concerning investments yielding exempt income during the year was entertained.
Short deduction of tax at source did not warrant disallowance under section 40(a)(ia), and the related royalty-characterisation questions were treated as academic. Corporate guarantee commission was upheld at 0.5% because a corporate guarantee to an associated enterprise is not comparable to a bank guarantee, so no substantial question of law arose. On section 14A, where the assessee's own and other non-interest-bearing funds exceeded tax-free investments, a presumption arose that the investments came from interest-free funds, defeating interest disallowance under Rule 8D(2)(ii). Only the re-framed question under section 14A read with Rule 8D(2)(iii) concerning investments yielding exempt income during the year was entertained.
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