Charitable registration turns on predominant purpose and genuine activities, while incidental fees and related-party rent require supporting adverse m...
MAT book-profit adjustments exclude disallowances for exempt-income expenditure and demerger expenditure unless expressly listed under the statutory c...
Omitted specified domestic transaction provision invalidates related-party expenditure transfer-pricing references and assessments based on consequent...
Preventive suspension requires an immediate continuing threat and cannot become indefinite without inquiry, fresh evidence, or proportionate safeguard...
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Credit rating and annual surveillance receipts were held not taxable as fees for technical services under the India-Singapore DTAA because the determinative test was whether technical know-how, skill, technology or process had been made available to the client. The Tribunal found that clients received only the rating output, not the underlying expertise or technology used to produce it, and no know-how was transferred. The addition was therefore deleted.
Credit rating and annual surveillance receipts were held not taxable as fees for technical services under the India-Singapore DTAA because the determinative test was whether technical know-how, skill, technology or process had been made available to the client. The Tribunal found that clients received only the rating output, not the underlying expertise or technology used to produce it, and no know-how was transferred. The addition was therefore deleted.
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